w w w . L a w y e r S e r v i c e s . i n



Pr Commissioner of Income Tax Bangalore v/s EDS Electronics Data Systems India Pvt. Ltd., Bangalore


Company & Directors' Information:- ELECTRONICS CORPORATION OF INDIA LIMITED [Active] CIN = U32100TG1967GOI001149

Company & Directors' Information:- L G ELECTRONICS INDIA PRIVATE LIMITED [Active] CIN = U32107DL1997PTC220109

Company & Directors' Information:- T V S ELECTRONICS LIMITED [Dissolved] CIN = U30006TN1986PLC013301

Company & Directors' Information:- C P SYSTEMS PVT LTD [Active] CIN = U29199DL1999PTC101718

Company & Directors' Information:- T SYSTEMS INDIA PRIVATE LIMITED [Strike Off] CIN = U72200DL2004PTC127138

Company & Directors' Information:- U K B ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109DL2004PTC126250

Company & Directors' Information:- M G ELECTRONICS LIMITED [Active] CIN = U74899DL1969PLC005030

Company & Directors' Information:- A K M SYSTEMS PRIVATE LIMITED [Active] CIN = U74899DL1984PTC018546

Company & Directors' Information:- J V ELECTRONICS PVT. LTD. [Active] CIN = U74899DL1973PTC006446

Company & Directors' Information:- AND DATA INDIA PRIVATE LIMITED [Active] CIN = U72200PN1998PTC016655

Company & Directors' Information:- AND DATA INDIA PRIVATE LIMITED [Strike Off] CIN = U99999MH1998PTC117230

Company & Directors' Information:- L B ELECTRONICS LIMITED [Active] CIN = U32109DL2005PLC134598

Company & Directors' Information:- R R ELECTRONICS PRIVATE LIMITED [Active] CIN = U31908MH2007PTC171298

Company & Directors' Information:- W B M SYSTEMS PRIVATE LIMITED [Active] CIN = U74899DL1984PTC017764

Company & Directors' Information:- B AND B ELECTRONICS LIMITED [Active] CIN = U74899DL1984PLC019600

Company & Directors' Information:- B R C ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109DL2005PTC140580

Company & Directors' Information:- A G T ELECTRONICS LIMITED [Active] CIN = U31200TZ1989PLC002336

Company & Directors' Information:- O S ELECTRONICS INDIA PRIVATE LIMITED [Active] CIN = U74900DL2015FTC283969

Company & Directors' Information:- J. C. ELECTRONICS PRIVATE LIMITED [Active] CIN = U51909GJ2010PTC061768

Company & Directors' Information:- A R G SYSTEMS LIMITED [Active] CIN = U74899DL1994PLC062621

Company & Directors' Information:- R A ELECTRONICS PRIVATE LIMITED [Active] CIN = U29308GJ1991PTC016804

Company & Directors' Information:- S SYSTEMS PVT LTD [Active] CIN = U72200DL2001PTC111270

Company & Directors' Information:- SYSTEMS INDIA PRIVATE LIMITED [Active] CIN = U74899DL1994PTC059377

Company & Directors' Information:- G S C ELECTRONICS PRIVATE LTD. [Active] CIN = U74899DL1987PTC029325

Company & Directors' Information:- J N J ELECTRONICS LIMITED [Active] CIN = U32101DL2005PLC142345

Company & Directors' Information:- S N ELECTRONICS PRIVATE LIMITED [Active] CIN = U32101AS1999PTC005696

Company & Directors' Information:- A D ELECTRONICS PRIVATE LIMITED [Amalgamated] CIN = U31200MH1996PTC104103

Company & Directors' Information:- R AND S (INDIA) ELECTRONICS PRIVATE LIMITED [Active] CIN = U29299MH2000PTC128688

Company & Directors' Information:- V S S SYSTEMS INDIA PRIVATE LIMITED [Strike Off] CIN = U03000TZ1997PTC007933

Company & Directors' Information:- ELECTRONICS LTD [Under Liquidation] CIN = U32201DL1945PLC000866

Company & Directors' Information:- DATA ELECTRONICS PVT LTD [Active] CIN = U32301WB1987PTC041940

Company & Directors' Information:- I L SYSTEMS INDIA PRIVATE LIMITED [Strike Off] CIN = U18100GJ1999PTC037104

Company & Directors' Information:- H R ELECTRONICS PRIVATE LIMITED [Active] CIN = U51395DL2000PTC107829

Company & Directors' Information:- A V SYSTEMS PRIVATE LIMITED [Active] CIN = U31909PN2001PTC015788

Company & Directors' Information:- N D T SYSTEMS PRIVATE LIMITED [Active] CIN = U74210MH1996PTC104744

Company & Directors' Information:- S P P S SYSTEMS PRIVATE LIMITED [Active] CIN = U72200TG2000PTC033732

Company & Directors' Information:- S P DATA PVT LTD [Strike Off] CIN = U72502WB1989PTC047578

Company & Directors' Information:- L S I SYSTEMS (INDIA) PRIVATE LIMITED [Active] CIN = U32109DL2000PTC105666

Company & Directors' Information:- H B S SYSTEMS PRIVATE LIMITED [Active] CIN = U74899DL1992PTC048198

Company & Directors' Information:- C M R ELECTRONICS PRIVATE LIMITED [Amalgamated] CIN = U72211WB1979PTC032091

Company & Directors' Information:- P R ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U31900KA1991PTC011572

Company & Directors' Information:- K V N ELECTRONICS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC074002

Company & Directors' Information:- M. R. ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109DL2008PTC185335

Company & Directors' Information:- L K ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109DL2006PTC144509

Company & Directors' Information:- K V ELECTRONICS PVT LTD [Strike Off] CIN = U32107TG1986PTC006103

Company & Directors' Information:- U C SYSTEMS INDIA PVT LTD [Active] CIN = U72200DL1997PTC084267

Company & Directors' Information:- A AND N ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109DL2006PTC144588

Company & Directors' Information:- S N A ELECTRONICS PRIVATE LIMITED [Active] CIN = U32204DL2009PTC188412

Company & Directors' Information:- S. B. DATA SYSTEMS PRIVATE LIMITED [Active] CIN = U72200MH1997PTC109612

Company & Directors' Information:- B J ELECTRONICS PRIVATE LIMITED [Active] CIN = U03210TZ1993PTC004634

Company & Directors' Information:- L C SYSTEMS PRIVATE LIMITED [Active] CIN = U55200PB2012PTC036880

Company & Directors' Information:- N U ELECTRONICS PVT LTD [Strike Off] CIN = U99999MH1981PTC025048

Company & Directors' Information:- H B ELECTRONICS PRIVATE LIMITED [Active] CIN = U32201GJ1988PTC010345

Company & Directors' Information:- C I SYSTEMS PVT LTD [Active] CIN = U45200TG1983PTC003915

Company & Directors' Information:- M J SYSTEMS (INDIA) PRIVATE LIMITED [Active] CIN = U72900MH2005PTC150591

Company & Directors' Information:- R R SYSTEMS PRIVATE LIMITED [Active] CIN = U30007DL1999PTC098142

Company & Directors' Information:- S M I C ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U51909DL2009PTC193590

Company & Directors' Information:- M M ELECTRONICS PRIVATE LIMITED [Active] CIN = U74899DL1987PTC030129

Company & Directors' Information:- D M ELECTRONICS PRIVATE LIMITED [Active] CIN = U31909DL1997PTC087620

Company & Directors' Information:- C N C SYSTEMS PVT LTD [Active] CIN = U72900DL1999PTC100476

Company & Directors' Information:- M. A. ELECTRONICS PRIVATE LIMITED [Active] CIN = U40101WB2007PTC121034

Company & Directors' Information:- D S ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109DL2004PTC126986

Company & Directors' Information:- S S G ELECTRONICS PRIVATE LIMITED [Active] CIN = U31909DL1998PTC092657

Company & Directors' Information:- M B M SYSTEMS PRIVATE LIMITED [Active] CIN = U30006DL1988PTC030404

Company & Directors' Information:- R S M ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U33111TN1987PTC014843

Company & Directors' Information:- C. G. ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U52334UP1992PTC014453

Company & Directors' Information:- S G ELECTRONICS PVT LTD [Strike Off] CIN = U31909WB1992PTC055977

Company & Directors' Information:- C S R ELECTRONICS PRIVATE LIMITED [Active] CIN = U32101DL1983PTC017212

Company & Directors' Information:- C. ELECTRONICS PVT. LTD. [Under Liquidation] CIN = U51433WB1991PTC052848

Company & Directors' Information:- C SYSTEMS PRIVATE LIMITED [Active] CIN = U31103TN2009PTC071155

Company & Directors' Information:- R M I SYSTEMS PRIVATE LIMITED [Active] CIN = U72200KA2011PTC060246

Company & Directors' Information:- V B ELECTRONICS PVT LTD [Active] CIN = U29308GJ1982PTC005087

Company & Directors' Information:- R G M ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109DL1998PTC096022

Company & Directors' Information:- N E B ELECTRONICS PRIVATE LIMITED [Under Liquidation] CIN = U32300MH2004PTC145675

Company & Directors' Information:- W & S SYSTEMS (INDIA) PRIVATE LIMITED [Active] CIN = U74910TN2005PTC055568

Company & Directors' Information:- M. Y. T. SYSTEMS PRIVATE LIMITED [Under Process of Striking Off] CIN = U74990TG2016PTC110104

Company & Directors' Information:- H D ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U29308WB2008PTC121476

Company & Directors' Information:- A G ELECTRONICS PRIVATE LIMITED [Active] CIN = U32109WB2007PTC116846

Company & Directors' Information:- V M K ELECTRONICS PRIVATE LIMITED. [Active] CIN = U31908DL2007PTC162969

Company & Directors' Information:- X-ON ELECTRONICS PRIVATE LIMITED [Active] CIN = U51909DL2021FTC381689

Company & Directors' Information:- S E I SYSTEMS LIMITED [Strike Off] CIN = L74899DL1994PLC061731

Company & Directors' Information:- D C S SYSTEMS LIMITED [Strike Off] CIN = U72100MP2000PLC014224

Company & Directors' Information:- I T G SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72200DL1999PTC098431

Company & Directors' Information:- R T S ELECTRONICS PVT LTD [Strike Off] CIN = U32109PB1986PTC006755

Company & Directors' Information:- B. T. ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U29309TG1998PTC030240

Company & Directors' Information:- I O SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72200TG1998PTC029166

Company & Directors' Information:- ELECTRONICS (INDIA) PVT LTD [Active] CIN = U29306WB1991PTC053380

Company & Directors' Information:- S N J ELECTRONICS PRIVATE LIMITED [Active] CIN = U32305DL2004PTC131140

Company & Directors' Information:- S E C O M SYSTEMS PRIVATE LIMITED [Active] CIN = U31909HR2009PTC039084

Company & Directors' Information:- C K ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U30007CH1999PTC023193

Company & Directors' Information:- A K G ELECTRONICS PRIVATE LTD [Strike Off] CIN = U31909DL1984PTC017616

Company & Directors' Information:- S L ELECTRONICS PRIVATE LIMITED [Active] CIN = U74899DL1984PTC019260

Company & Directors' Information:- H B S A ELECTRONICS PRIVATE LIMITED [Active] CIN = U29309PB1995PTC017227

Company & Directors' Information:- A A ELECTRONICS PRIVATE LIMITED [Active] CIN = U74899DL1988PTC031562

Company & Directors' Information:- DATA SYSTEMS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U72900MH1999PTC121321

Company & Directors' Information:- R K G ELECTRONICS PRIVATE LIMITED [Active] CIN = U29191DL1996PTC075531

Company & Directors' Information:- D M SYSTEMS PRIVATE LIMITED [Active] CIN = U72100DL1999PTC101817

Company & Directors' Information:- H K ELECTRONICS PRIVATE LIMITED [Converted to LLP] CIN = U32200MH1992PTC067704

Company & Directors' Information:- S M C ELECTRONICS PRIVATE LIMITED [Active] CIN = U29248UR2015PTC001680

Company & Directors' Information:- D V G ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U40300UP2015PTC072080

Company & Directors' Information:- E K ELECTRONICS PRIVATE LIMITED [Active] CIN = U31900PN2010PTC135750

Company & Directors' Information:- K K K SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72100UP1995PTC017784

Company & Directors' Information:- A B ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74899DL2000PTC103497

Company & Directors' Information:- L P ELECTRONICS PVT LTD [Strike Off] CIN = U72200WB1980PTC033179

Company & Directors' Information:- E-SYSTEMS (INDIA) PRIVATE LIMITED [Active] CIN = U72200WB2003PTC096700

Company & Directors' Information:- K M S ELECTRONICS PVT LTD [Strike Off] CIN = U52335WB1994PTC065698

Company & Directors' Information:- R M ELECTRONICS PVT LTD [Strike Off] CIN = U32109WB1988PTC045429

Company & Directors' Information:- R V ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U31909PN2003PTC017582

Company & Directors' Information:- P C S L ELECTRONICS PVT LTD [Active] CIN = U51505WB1996PTC077466

Company & Directors' Information:- A H S ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74899DL1989PTC037364

Company & Directors' Information:- D V C ELECTRONICS INDIA PRIVATE LIMITED [Strike Off] CIN = U32201DL1996PTC077906

Company & Directors' Information:- K J ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U29299MH1996PTC099288

Company & Directors' Information:- K R A ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32109DL2005PTC140367

Company & Directors' Information:- A C R ELECTRONICS PRIVATE LIMITED [Active] CIN = U29100KA2013PTC071197

Company & Directors' Information:- N N ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74899DL1994PTC058398

Company & Directors' Information:- U V ELECTRONICS PVT LTD [Strike Off] CIN = U29308MP1985PTC002738

Company & Directors' Information:- J B SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72200KL1997PTC011510

Company & Directors' Information:- EDS INDIA PVT LTD [Strike Off] CIN = U31909DL1997PTC084963

Company & Directors' Information:- INDIA ELECTRONICS LIMITED [Under Liquidation] CIN = U99999RJ1981PLC002349

Company & Directors' Information:- M AND S SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72200MH1996PTC103819

Company & Directors' Information:- K AND M SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U32101UP1993PTC015352

Company & Directors' Information:- C R ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32103MH1979PTC021696

Company & Directors' Information:- DATA Q & S SYSTEMS INDIA PRIVATE LIMITED [Strike Off] CIN = U72200TN2008PTC066220

Company & Directors' Information:- S S V SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72300TN1996PTC037072

Company & Directors' Information:- R G B SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72300TN1998PTC040485

Company & Directors' Information:- A. C. ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32100TG1997PTC027030

Company & Directors' Information:- C C SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U31100TG1996PTC023469

Company & Directors' Information:- B R B ELECTRONICS PVT LTD [Strike Off] CIN = U31100TG1994PTC018195

Company & Directors' Information:- E-DATA SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72300WB2007PTC117869

Company & Directors' Information:- A K ELECTRONICS PVT LTD [Strike Off] CIN = U00379BR1986PTC002265

Company & Directors' Information:- L AND S ELECTRONICS PRIVATE LIMITED [Active] CIN = U74899DL1980PTC011153

Company & Directors' Information:- A S ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74899DL1990PTC042519

Company & Directors' Information:- F M S ELECTRONICS PRIVATE LIMITED. [Strike Off] CIN = U32109CH1988PTC008596

Company & Directors' Information:- A M K ELECTRONICS PVT LTD [Active] CIN = U32301CH1980PTC004291

Company & Directors' Information:- K R T SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U52392TN2002PTC048704

Company & Directors' Information:- B L R S (ELECTRONICS) PRIVATE LIMITED [Strike Off] CIN = U33111TN1976PTC007083

Company & Directors' Information:- S M S DATA SYSTEMS PVT LTD [Strike Off] CIN = U72300WB1988PTC045145

Company & Directors' Information:- K G ELECTRONICS PRIVATE LIMITED [Active] CIN = U74899DL1987PTC027723

Company & Directors' Information:- U S ELECTRONICS PVT LTD [Amalgamated] CIN = U32109MH1981PTC024519

Company & Directors' Information:- B & D SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72100OR1996PTC004611

Company & Directors' Information:- A M P S SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72900WB2001PTC093281

Company & Directors' Information:- U A ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74899DL1997PTC090003

Company & Directors' Information:- G P ELECTRONICS PVT LTD [Strike Off] CIN = U31103WB1983PTC035762

Company & Directors' Information:- G R ELECTRONICS PVT LTD [Strike Off] CIN = U32101PB1985PTC006219

Company & Directors' Information:- G M E SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U71290DL1987PTC029758

Company & Directors' Information:- J L ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U31900KA1995PTC018631

Company & Directors' Information:- R B SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U31300RJ1990PTC005689

Company & Directors' Information:- S. M. G. ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32107DL1986PTC023467

Company & Directors' Information:- I D S ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32109DL1995PTC074417

Company & Directors' Information:- P C ELECTRONICS PVT LTD [Strike Off] CIN = U32301CH1994PTC015359

Company & Directors' Information:- S V ELECTRONICS LIMITED [Strike Off] CIN = U29309TG1999PLC031988

Company & Directors' Information:- E D H SYSTEMS PVT. LTD. [Strike Off] CIN = U99999DL1991PTC045384

Company & Directors' Information:- H P ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U29100PN2011PTC138672

Company & Directors' Information:- H N G SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72900RJ2012PTC040713

Company & Directors' Information:- F A SYSTEMS PRIVATE LIMITED [Active] CIN = U72100MH2004PTC148941

Company & Directors' Information:- P T ELECTRONICS PRIVATE LIMITED [Active] CIN = U31909MH1999PTC119296

Company & Directors' Information:- S I ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74900PN2010PTC136038

Company & Directors' Information:- H AND P SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U74900PN2013PTC146918

Company & Directors' Information:- I. V. ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U51909MH2011PTC214508

Company & Directors' Information:- G. K. SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72900PN2006PTC129225

Company & Directors' Information:- T G SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U31403TN2006PTC061859

Company & Directors' Information:- R N D ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74900JK2011PTC003270

Company & Directors' Information:- P B ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32109HP1997PTC019625

Company & Directors' Information:- I T SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72400AS1999PTC005824

Company & Directors' Information:- Y Y SYSTEMS PRIVATE LIMITED [Active] CIN = U72200CH2015PTC035767

Company & Directors' Information:- N P M E SYSTEMS PRIVATE LIMITED [Active] CIN = U29299DL1998PTC094645

Company & Directors' Information:- K S K ELECTRONICS PRIVATE LIMITED [Active] CIN = U31101DL2006PTC148357

Company & Directors' Information:- Y P ELECTRONICS PRIVATE LIMITED [Active] CIN = U31401DL2009PTC189107

Company & Directors' Information:- A R ELECTRONICS PRIVATE LTD. [Active] CIN = U74899DL1985PTC022843

Company & Directors' Information:- U P S ELECTRONICS PRIVATE LIMITED [Active] CIN = U74899DL1987PTC027323

Company & Directors' Information:- E S SYSTEMS & ELECTRONICS PRIVATE LIMITED [Active] CIN = U74140DL2015PTC329735

Company & Directors' Information:- INDIA X-ON ELECTRONICS PRIVATE LIMITED [Active] CIN = U51909DL2017PTC311261

Company & Directors' Information:- A B J ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U74999DL2011PTC226921

Company & Directors' Information:- R D SYSTEMS PRIVATE LIMITED [Active] CIN = U72100DL2000PTC103462

Company & Directors' Information:- V C SYSTEMS PVT LTD [Active] CIN = U72200DL2001PTC111812

Company & Directors' Information:- K B N SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U64204DL1997PTC088904

Company & Directors' Information:- A B SYSTEMS PRIVATE LIMITED [Active] CIN = U93000DL2012PTC234774

Company & Directors' Information:- T H ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32109DL1996PTC075539

Company & Directors' Information:- U AND U ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32109DL2001PTC112361

Company & Directors' Information:- A AND W ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32109DL2005PTC139906

Company & Directors' Information:- V N ELECTRONICS PRIVATE LIMITED [Active] CIN = U32200DL2009PTC188507

Company & Directors' Information:- J & H ELECTRONICS PRIVATE LIMITED [Active] CIN = U32204DL2015PTC276268

Company & Directors' Information:- B N ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32210DL2000PTC107871

Company & Directors' Information:- E S SYSTEMS & ELECTRONICS PRIVATE LIMITED [Active] CIN = U74140HR2015PTC056237

Company & Directors' Information:- BANGALORE ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U00349KA1987PTC008427

Company & Directors' Information:- PR SYSTEMS PRIVATE LIMITED [Active] CIN = U74999HR2017PTC069079

Company & Directors' Information:- ON ELECTRONICS PRIVATE LIMITED [Active] CIN = U74990KA2009FTC083028

Company & Directors' Information:- J S N D SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72900GJ2011PTC065160

Company & Directors' Information:- S V S ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32300DL1993PTC053405

Company & Directors' Information:- J C D SYSTEMS PVT LTD [Strike Off] CIN = U32109PB1988PTC008438

Company & Directors' Information:- V R ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U31101KA1975PTC002784

Company & Directors' Information:- H V M ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U31200UP1988PTC010212

Company & Directors' Information:- Y R SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72900DL2000PTC105093

Company & Directors' Information:- S R SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72900DL2000PTC104743

Company & Directors' Information:- F C S SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U73100DL1997PTC090517

Company & Directors' Information:- P AND A ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U32109DL1990PTC040859

Company & Directors' Information:- BANGALORE ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U31909KA1967PTC001689

Company & Directors' Information:- L P ELECTRONICS PRIVATE LIMITED [Active] CIN = U99999MH1974PTC017722

Company & Directors' Information:- E R SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72200TG2008PTC061904

Company & Directors' Information:- S R ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U99999DL1988PTC034382

Company & Directors' Information:- R & T SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U72200DL2008PTC179617

Company & Directors' Information:- Q S Q SYSTEMS PRIVATE LIMITED [Strike Off] CIN = U51109KA2000PTC026269

Company & Directors' Information:- B D S ELECTRONICS PRIVATE LIMITED [Strike Off] CIN = U00369KA1975PTC002735

Company & Directors' Information:- A. M. ELECTRONICS PVT. LTD. [Strike Off] CIN = U36997WB1981PTC033742

    Income Tax Appeal No. 680 of 2015

    Decided On, 15 January 2021

    At, High Court of Karnataka

    By, THE HONOURABLE MR. JUSTICE ALOK ARADHE & THE HONOURABLE MR. JUSTICE NATARAJ RANGASWAMY

    For the Appearing Parties: T.N.C. Sridhar, T. Suryanarayana, Advocates.



Judgment Text

Alok Aradhe, J.This appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) has been preferred by the revenue. The subject matter of the appeal pertains to the Assessment year 2004-05. The appeal was admitted by a bench of this Court vide order dated 24.08.2016 on the following substantial question of law:"Whether the Tribunal is correct in law and facts in upholding the Commissioner of Income Tax (Appeals)'s order ignoring the basic mistake therein that having accepted Transaction Net Margin Method and the Profit Level Indicator as OP/TC when the application of the Profit Level Indicator on the total cost is proper and not on the payments made to the Associated enterprises?".2. Facts leading to filing of this appeal briefly stated are that the respondent provides its technical consultancy services to third parties and operate as entrepreneur. The business of providing technical consultancy services is an independent business segment. The parent company of the assessee is EDS Sweden and another Swedish company i.e., SKF AB had entered into a Master Service Agreement. As per the aforesaid agreement, EDS entities across the globe had to provide IT services to SKF entities in their respective regions. In pursuance of the Master Service Agreement, the assessee entered into a local / domestic contract with SKF India for providing IT services. The assessee bears all the entrepreneurial risks associated with the contract with SKF India.3. Apart from SKF India, the assessee also entered into various other contracts with other third parties for rendering technical services. The revenue from the technical consultancy services segment of the assessee is thus derived from a number of contracts including SKF India, which have been entered by the respondent globally and locally. Although, the technical consultancy services segment made a loss of 14.76%, the respondent was able to bifurcate the revenues and costs on the basis of SKF and non SKF contracts and profitability of the technical consultancy segment from SKF contract and non SKF contract was -103% and 36% respectively. Thus, the technical consultancy service segment was profitable segment, whereas, SKF contract was loss making contract. The respondent also availed of certain assistance of its group entities across the globe and one such entity was EDS Singapore, for which assessee had paid cost plus 10% mark-up, which was used by non Indian EDS entities globally. The aforesaid payment was made by EDS India to EDS Singapore, which includes the cost of services of all other segments of EDS India as well and does not pertain to technical consultancy segment alone.4. The assessee claimed the benefit of deduction under Section 10A of the Act in respect of profits derived from export of software STP Units and claimed deduction under Section 80HHE in respect of profits derived from export of computer software available to any entity. However, the Transfer Pricing Officer by order dated 06.05.2006 considered the loss of 14.76% in the entire technical consultancy services agreement and was of the view that since, independent parties had an average margin of 17.02% therefore, there ought to be an adjustment. Thus, an adjustment of Rs.7,91,44,777/- was made. Thereafter, the Assessing Officer by an order dated 26.12.2006 under Section 143(3) of the Act assessed the income at Rs.33,98,72,603/- after making disallowances with regard to addition on account of income from other sources, addition on account of foreign exchange loss and addition on account of Arms Length Price (ALP).5. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals) who by an order dated 21.01.2009 inter alia held that respondent has earned a profit in technical service segment in contracts other than contracts with SKF India, the Transfer Pricing Officer (TPO) should not have loaded the mark-up on the costs / expenses in meeting the obligations other than the contracts with SKF India, on which the assessee had earned 36% profits. Accordingly, the Commissioner of Income Tax (Appeals) reduced the Transfer Pricing Adjustment from Rs.7,91,44,777/- to Rs.1,29,43,376/- by meeting the adjustment to SKF contract. Being aggrieved, the assessee as well as the revenue filed appeals before the Income Tax Appellate Tribunal (hereinafter referred to as 'the tribunal' for short). In order to bring the quietus to the controversy, the assessee did not prosecute its appeal, whereas, the tribunal by an order dated 23.06.2015 dismissed the appeal preferred by the revenue. In the aforesaid factual background, this appeal has been filed.6. Learned counsel for the revenue submitted that the Transfer Pricing Officer/ has adopted transaction net method or bench marking cost as the profit level indicator and the Commissioner of Income Tax (Appeals) has confirmed the aforesaid finding of the Transfer Pricing Officer. It is submitted that having concurred with the finding recorded by the Transfer Pricing Officer on the method adopted by him, the Commissioner of Income Tax (Appeals) ought to have held that the adjustment has to be restricted to SKF contracts, which has made losses and by adopting transaction net margin method, the profit margin of 17.02% ought to have been applied on the total cost of Rs.17,11,64,696/- and therefore, mistake in computation of the adjustment in the order of the Commissioner of Income Tax needs to be corrected. It is also submitted that the Transfer Pricing Officer had adopted a method in accordance with Section 92 read with Rule 10B of the Act and therefore, re-computation of Arms Length Price made by Commissioner of Income Tax (Appeals) and the tribunal is not correct. It is further submitted that the tribunal has failed to assign any reasons for disturbing the findings of Transfer Pricing Officer that arithmetic mean of 17.02% of the comparables determined for Arms Length Price computation is erroneous.7. On the other hand, learned counsel for the assessee submitted that only the revenues from the contract entered into between the assessee and SKF India if at all could be subjected to Arms Length Price test which has been held by the Commissioner of Income Tax (Appeals) as well as by the tribunal. It is further submitted that making an adjustment to the entire segment merely because transactional net margin method is applied would lead to unintended consequences which would give rise to unnecessary load being created on a segment which is otherwise profitable. It is further submitted that where there are no international transactions or where the price of international transaction is already at arms length no adjustment can be made. It is further submitted that the revenue has neither challenged the findings of the tribunal as being perverse nor has brought any material on record to demonstrate perversity. Therefore, in view of concurrent findings of fact recorded by the tribunal no substantial question of law arises for consideration. In support of aforesaid submissions, reliance has been placed on decisions of the Supreme Court in 'SUDARSHAN SILKS & SAREES VS. COMMISSIONER OF INCOME-TAX, (2008) 169 TAXMAN 321 (SC) and a decision of this court in PCIT AND ANOTHER VS. SAMSUNG R & D INSTITUTE BANGALORE PVT. LTD. I.T.A.NO.622/2017 DATED 30.11.2020.8. We have considered the submissions made by learned counsel for the parties and have perused the record. Section 92(1) of the Act provides that any income arising from an international transaction shall be computed having regard to Arms Length Price. Section 92B(1) deals with meaning of international transaction, which means a transaction between two or more associated enterprises either or both of whom are non residents in the nature of purchase, sale or lease of tangible or intangible property or provisions of services or rendering or borrowing money. Section 92C of the Act deals with computation of Arms Length Price. The Commissioner of Income Tax (Appeals) has recorded a finding that since the assessee had earned profit in a technical service segment in contracts other than contracts with SKF and therefore, the Transfer Pricing Officer should not have loaded the mark-up on the costs / expenses incurred in meeting the obligations under contracts other than the contracts with SKF on which the assessee had earned a profit of 36% on operating cost. The aforesaid finding of fact has been affirmed in appeal by the tribunal. The aforesaid findings are findings of fact, which

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have been arrived at by the Commissioner of Income Tax (Appeals) as well as the tribunal on the basis of meticulous appreciation of evidence on record.9. It is the cardinal principle of law that tribunal is fact finding authority and a decision on facts on the tribunal can be gone into by the High Court only if a question has been referred to it, which says the finding of the tribunal is perverse. [SEE: 'SUDARSHAN SILKS & SAREES VS. CIT, (2008) 300 ITR 205 SCC @ 211 and 'MANGALORE GANESH BEEDI WORKS VS. CIT, (2015) 378 ITR 640 (SC) @ 648]. It is pertinent to note that even in the substantial question of law, no element of perversity is either pleaded or demonstrated before this court. In view of preceding analysis, the substantial question of law framed by a bench of this court is answered against the revenue and in favour of the assessee. In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed.
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