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M/S. Evolving Systems Network India ... vs Assistant Commissioner Of Income Tax, ... on 24 September, 2021 cites

Maxim India Integrated Circuit Design ... vs Dcit, Bangalore on 5 January, 2021

Both these decisions have been considered in the Bengaluru Bench of the Tribunal rendered in the case of Maxim India Integrated Circuit Design Pvt. Ltd., (supra). The Tribunal, after noticing the fact that in the decision cited in the order of the DRP, the facts were different and would result in the same effect if the claim of the assessee is accepted.
Income Tax Appellate Tribunal - Bangalore Cites 9 - Cited by 14 - Full Document

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

"47. In Ground No. 10 the assessee pointed out to the mistakes in computation of PLI. It was submitted that the TPO has considered provision for doubtful debts and provision for doubtful advances are non-operating in nature and the action was upheld by the DRP. In this regard it was submitted that provision for doubtful debts is a provision which is to be made as a part of the operating activities of business governed by the principles of prudence, and therefore it is not correct to contend that the same is non-operating in nature. Reliance in this regard is placed on the decision of the Delhi Bench of the Tribunal in the case of Rolls-Royce India (P.) Ltd. v. DCIT [2016] 69 taxmann.com 209 (Delhi - Trib.). Therefore it was submitted that the aforesaid items are to be treated as being operating in nature.
Income Tax Appellate Tribunal - Bangalore Cites 141 - Cited by 387 - Full Document

Jas Forwarding Worldwide Pvt. Ltd., New ... vs Dcit, New Delhi on 26 July, 2021

8. Learned Counsel brought to our notice the decision of the Tribunal rendered in the case of ACI Worldwide Solutions Pvt. Ltd., Vs. DCIT in IT(TP)A No.1893/Bang/2017 order dated 27.09.2019 wherein this Tribunal decided identical issue in favour of the assessee by following the decision of the Hon'ble Karnataka High Court in the case of Pr.CIT Vs. Business Process Outsourcing India Pvt. Ltd., (2018) taxcorp (DT) 73195 (HC Karnataka). The following were the relevant observations of the Tribunal:
Income Tax Appellate Tribunal - Delhi Cites 16 - Cited by 2 - Full Document

Four Seasons Wines Ltd, Bengaluru vs Deputy Commissioner Of Income Tax ... on 8 March, 2021

15. Before us, the Ld D.R placed his reliance on the decision rendered by Mumbai bench of Tribunal in the case of Thyssen Krupp Industries Ltd (supra). We notice that the assessee has claimed that the Provision for doubtful debts as non-operating in nature, which was not accepted by the TPO. The Tribunal accepted the submission of the assessee and accordingly it has held that it is a non-operating in nature. Thus, we notice that the above said decision has been rendered by the Mumbai bench of Tribunal in a different context. In the case of Telcordia Technologies India P Ltd, the Tribunal has made following observations in respect of Provision for doubtful debts, while considering the company named M/s R Systems International Ltd:-
Income Tax Appellate Tribunal - Bangalore Cites 1 - Cited by 2 - Full Document

The Pr. Commissioner Of Income Tax vs M/S Business Process Outsourcing India ... on 8 February, 2019

Besides the above, the Karnataka High Court has also taken a view in the case of Business Process Outsourcing India Pvt. Ltd., (supra) that provision for bad and doubtful debts should be taken as operating expenses while computing profit level indicator of the comparable companies. In the light of the aforesaid decisions which have been cited at the time of hearing of the appeal, we are of the view that the claim of the assessee deserves to be accepted. Accordingly, ground No.4(h) raised by the assessee has to be allowed and is hereby allowed.
Supreme Court - Daily Orders Cites 0 - Cited by 2 - Full Document

The Principal Commissioner Of Income ... vs M/S Business Process Outsourcing ... on 16 September, 2019

"8. As far as the exclusion of provision of bad and doubtful debts from the operating cost of the comparable companies is concerned, the learned Counsel for the assessee brought to our notice that while considering the international transaction in the distribution segment, the TPO has himself considered provision for bad and doubtful debts as part of the operating expenditure and by the same logic he should have treated provision for bad and doubtful debts as part of the operating cost in the hands of the comparable companies also. As far as the software development segment of the assessee is concerned, there is no provision for bad and doubtful debts. The learned Counsel for the assessee filed before us copy of the decision of the Hon'ble Karnataka High Court in the case of Principal CIT Vs. Business Process Outsourcing India Pvt. Ltd., (2018) taxcorp (DT) 73195 (HC Karnataka) wherein in an appeal against the order of the Tribunal holding that provision for bad and doubtful debts should be considered as part of the operating expenditure, the Hon'ble High Court confirmed the order of the Tribunal and dismissed the appeal of the Revenue as one not giving rise to any substantial question of law.
Supreme Court - Daily Orders Cites 0 - Cited by 4 - Full Document
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