Search Results Page

Search Results

1 - 5 of 5 (0.36 seconds)
Drg Analytics And Insights Private ... vs The Assistant Commissioner Of ... on 29 April, 2026 cites

M/S Apex Laboratories P. Ltd. vs The Deputy Commissioner Of Income Tax ... on 22 February, 2022

Ltd. vs. Deputy Commissioner of Income tax reported in [2022] 142 taxmann.com 482 (Bangalore - Trib.) dated [27-07-2022], the Tribunal has cautioned that selection or rejection of comparables without proper examination of functions, assets and risks or without analysing annual reports amounts to cherry picking on the part of the TPO itself.
Supreme Court of India Cites 41 - Cited by 189 - S R Bhat - Full Document

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

38.2 The Tribunal in several cases consistently held that where the underlying transaction is in foreign currency, the appropriate benchmark rate is LIBOR plus a reasonable basis point spread. We find force in the following judicial precedents in the jurisdictional Bangalore ITAT in the case of Synechron Technologies (P.) Ltd vs. ACIT [2025] 175 taxmann.com 404 (Bangalore - Trib.) [04-06-2025]. The relevant para is reproduced below:
Income Tax Appellate Tribunal - Bangalore Cites 68 - Cited by 4 - Full Document

Vodafone Idea Ltd(Earlier Known As ... vs Assistant Commissioner Of Income Tax ... on 29 April, 2020

18. We have carefully considered the rival submissions and perused the material available on record. The issue for consideration is whether comparables can be included or excluded solely on the basis of their presence or absence in the search matrix and what constitutes "cherry picking" in the context of transfer pricing analysis. At the outset, we note that there are divergent views expressed by coordinate benches on this issue. In Concur Technologies (India) (P.) Ltd. vs. Assistant Commissioner of Income-tax, reported in [2025] 180 taxmann.com 447 (Bangalore - Trib.) dated [11-11-2025], the Tribunal has emphasised .
Supreme Court of India Cites 51 - Cited by 78 - U U Lalit - Full Document

M/S. Curam Software International ... vs Income Tax Officer, Ward-2(1)(2), ... on 22 February, 2019

18.4 Similarly, the TPO cannot rely upon the search matrix to justify selection or rejection of comparables without undertaking proper FAR analysis. Mechanical application of filters or superficial examination of comparables, without analysing their actual functions and financials, would also amount to cherry picking, as held in IG Infotech and Quicklogic Software (supra). Accordingly, the following principles emerge:
Income Tax Appellate Tribunal - Bangalore Cites 3 - Cited by 0 - Full Document

Agilent Technologies (International) ... vs Acit, Circle-1(1), Gurgaon on 10 June, 2022

33.2 Hence, in the interest of justice and fair-play, we deem it appropriate to restore this issue to the file of the AO/TPO for the limited purpose of granting working capital adjustment in accordance with law. The AO/TPO is directed to compute the working capital adjustment in line with the principles laid down in Agilent Technologies (International) P. Ltd. vs. ACIT reported in [2025] 172 taxmann.com 858 (Delhi - Trib.), as detailed under:
Income Tax Appellate Tribunal - Delhi Cites 0 - Cited by 0 - G S Pannu - Full Document
1