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Documents citing Google India Private Limited, ... vs The Deputy Commissioner Of Income Tax ... on 11 May, 2018

A1 Telekom Austria ... vs Dcit, International Taxation, ... on 5 August, 2025

IT(IT)A No.666/Bang/2025 Page 23 of 24 SWD services to its AEs. Similarly, the Hon'ble ITAT Bangalore in the case of NTT Data Information Processing Services (P.) Ltd vs. DCIT (154 taxmann.com 460) [Refer Pg 123 & 124 of the Legal PB] also excluded a company providing software testing and QA services in the final list of comparables in the case of an assessee company providing SWD services to its AEs.
Income Tax Appellate Tribunal - Bangalore Cites 16 - Cited by 0 - Full Document

Amd India Private Limited, Bengaluru vs Acit, Circle-1(1)(1), Bangalore on 26 June, 2023

40.2 The ld. AR submitted that the Company is functionally different as it provides licensable software products for speech, video, fax and analog modem communications market. Relevant extract of website and submissions are placed at Pg 966-969 of PB I. He relied on the decision of ITAT Hyderabad in the case of Conexant Systems (P.) Ltd. v. DCIT [2018] 91 taxmann.com 308 for AY 11-12, wherein Consilient Technologies Pvt Ltd is rejected on functionality basis and submitted that this company is to be excluded.
Income Tax Appellate Tribunal - Bangalore Cites 68 - Cited by 4 - Full Document

M/S. Dell International Services India ... vs Joint Commissioner Of Income-Tax, ... on 6 December, 2021

9.1.3 We have considered the rival submissions as well as the relevant material on record. We find that the assessee has raised objections against this company before the DRP. However the DRP did not adjudicate the objections raised by the assessee. The decision of this Tribunal in the case of M/s. Electronics for Imaging India (P.) Ltd. v. DCIT (supra) relied upon by the learned Authorised Representative is based on two aspects (i) The information received under Section 133(6) of the Act was considered by the TPO without sharing with the assessee and (ii) nature of the activity is KPO. It is pertinent to note that the question of BPO and KPO is relevant only in ITES segment and not for software development services segment. On the contrary, the decision in the case of Toluna India (P.)
Income Tax Appellate Tribunal - Bangalore Cites 20 - Cited by 0 - Full Document

Praxair India Private Limited, ... vs Deputy Commissioner Of Income Tax, ... on 14 June, 2023

"8. We have considered the issue and examined the rival contentions. There is no dispute with reference to the fact that the CCDs were issued in Indian Rupees. Accordingly, following the principles laid down by the Coordinate Benches and the Hon 'ble High Court as relied on by the assessee in the submissions, we have to hold that TPO has wrongly treated the issuance of CCDs as a loan, by treating it as an external commercial borrowing, ignoring the fact that loan is a debt, whereas CCD is hybrid instrument in nature basically, categorised as equity in nature.
Income Tax Appellate Tribunal - Bangalore Cites 30 - Cited by 0 - Full Document

Arm Embedded Technologies Pvt Ltd , ... vs Deputy Commissioner Of Income Tax ... on 8 June, 2023

(i) Avnet India (P.) Ltd. v. DCIT (reported in [2016] 65 taxmann.com 187 (Bangalore-Trib)): The appeal against the above order came to be dismissed by the Hon'ble High Court of Karnataka IT(TP)A No.899/Bang/2022 M/s. Arm Embedded Technologies Pvt. Ltd., Bangalore Page 33 of 36 in PCIT and anr. V. Avnet India (P.) Ltd. (Order dated 01.08.2018 passed by the Hon'ble High Court of Karnataka in ITA No. 358/2016).
Income Tax Appellate Tribunal - Bangalore Cites 17 - Cited by 0 - Full Document

M/S Marvell India Pvt Ltd , Bangalore vs Assistant Commissioner Of Income Tax, ... on 27 November, 2018

2. In course of hearing before us, it was submitted by ld. AR of assessee that this issue was decided by the Tribunal as per para no. 7 of the impugned Tribunal order. He submitted that while dealing with the Tribunal order on which reliance has been placed by ld. AR of assessee in course of hearing having been rendered in the case of Kenexa Technologies (P.) Ltd. Vs. DCIT as reported in 51 taxmann.com 282 (Hyderabad-Trib.) copy available on pages 345 to 357 of case law compilation filed in course of hearing of this appeal, the Tribunal has considered the wrong para of this Tribunal order and the correct para which should have been considered by the Tribunal are paras 40 to 42 of this Tribunal order. It can be seen from page no. 43 of the M.P. because copy of this Tribunal order is filed by the assessee along with the MP also. It was submitted by him that these correct paras of this Tribunal order should be considered and the issue should be decided by considering these paras of this Tribunal order.
Income Tax Appellate Tribunal - Bangalore Cites 5 - Cited by 0 - Full Document
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