Search Results Page
Search Results
1 - 10 of 51 (1.52 seconds)The Income Tax Act, 1961
Google India Private Limited, ... vs The Deputy Commissioner Of Income Tax ... on 11 May, 2018
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.
Adp Pvt. Ltd., Hyd, Hyderabad vs Dcit, Circle-1(1), Hyderabad, ... on 28 February, 2017
not available. (Pg 206 2.This company passes all
of Appeal Papers. filters applied by the TPO
(Submission at Pg 879-880 of
DRP PB I and relevant extract of AR
1.Unreliable data at Pg 1399, 1413-1415 of PB
provided in annual II).
report with regard to 3.The Appellant relies on the
export revenue (Pg 84- following decision:
85 of Appeal Papers) • Quicklogic Software (India)
Pvt. Ltd. vs DCIT, Circle-
3(1)(1), Bengaluru
(IT(TP)A No.
181/Bang/2022) for AY
2017-18 (Para 13.1 to 13.3
at Page 1370 of PB-II-Case
law Compilation)
• ADP Pvt. Ltd., Hyderabad
vs DCIT-1(1), Hyderabad
(TS-63-ITAT-2022 Hyd) for
AY 2016-17 (Para 12.4 of
Pg 1288 of PB-II Case Law
compilation).
TPO 1.The company is listed in
1.The company was databases & financial data is
rejected as it did not available on public domain and
form part of search databases for analysis.
matrix (Pg 206 of 2.The company is functionally
Appeal Papers. similar as it provides solutions
E-Zest Solutions and services in product
Limited DRP engineering and software
1.Upheld the contention development. (Submission at
of the TPO (Pg 85 of Pg 880-881 of PB I).
Appeal Papers) 3. This company passes all
filters applied by the TPO
(Submission at Pg 882 of PB
I).
IT(TP)A Nos. 238/Bang/2021
& 262/Bang/2022
Page 121 of 133
DRP 1. The financial data relating to
1.This company does this company is available in
not appear in the search public domain.
matrix of the TPO (Pg 2.The company is functionally
90 of Appeal Papers).
similar as it provides
consultancy and technology
services in the area of Business
Nitor Infotech Private intelligence, collaboration,
Limited portals and performance
management domain
(Submission at Pg 894-895 of
PB I).
3. This company passes all
filters applied by the TPO
(Submission at Pg 895 of PB
I).
DRP 1.The company is functionally
1.The company is not similar as it is primarily
comparable because it engaged in software consulting
is engaged in and development. (submission
diversified activities,
Sasken at Pg 896 of PB I.)
has R&D activities and
Communication
owns patents (Pg 90-91
Technologies Limited 2.The company passes all
of Appeal Papers)
filters as applied by the TPO
(submission at Pg 897-898 of
PB I).
Section 234B in The Income Tax Act, 1961 [Entire Act]
Section 263 in The Income Tax Act, 1961 [Entire Act]
M/S.Sundaram Fin.Ltd vs Asst.Commissioner Of Income ... on 11 September, 2012
3. Market Tools Research India (P.) Ltd. v. Asstt. CIT [2013] 32
taxmann.com 358/[2014] 150 ITD 296 (Hyd.)
9.4 Ld. AR also submitted the comparative tables on depreciation
as below:
Global Logic India Limited, Delhi vs Dcit Tpo-2(1)(1), Delhi on 23 November, 2022
21. We have heard the rival submissions and perused the materials
available on record. This comparable has considered in the case of Global
Logic India Pvt. Ltd. v. DCIT (2022) 134 Taxmann.com 35 for the
assessment year 2016-17, wherein held as under:-
M/S. Yahoo Software Development India ... vs The Joint Commissioner Of Income Tax, ... on 28 February, 2020
• M/s. Yahoo Software Development India Pvt. Ltd. vs
JCIT, Special Range - 7, Bengaluru IT(TP)A No.
178/Bang/2022 for AY 2017-18
• ADP Pvt. Ltd., Hyderabad vs DCIT-1(1), Hyderabad for
AY 2016-17 (TS-63-ITAT-2022 Hyd)
40.30 The ld. DR relied on the orders of lower authorities.