NETRADYNE TECHNOLOGY INDIA PRIVATE LIMITED,BENGALURU V. INCOME TAX OFFICER, WARD-5(1)(1), BENGALURU

ITA 2258/BANG/2024

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Netradyne Technology India Pvt. Limited appealed against the assessment order for the assessment year 2021-22, which included significant additions to its income based on the arm's length price (ALP) of international transactions. The Income Tax Officer and the Transfer Pricing Officer had conducted a detailed analysis, rejecting the appellant's transfer pricing documentation and adopting a different set of comparables, leading to a higher ALP. The Tribunal examined the selection of comparables, the application of filters in the transfer pricing study, and the issue of working capital adjustments, ultimately deciding to exclude certain comparables and restore the working capital adjustment issue for further examination.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 775279 (ITAT-BANGALORE)
• Duration Of Justice: 9 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-09-2025
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: C
• Assessment Year: 2021-2022
• Appeal Filed On: 23-11-2024
• Other Referred Cases: Pentair Water India (P.) Ltd. vs. Additional Commissioner of Income-tax, Goa, PCIT v. Barclays Technology Centre Pvt. Ltd.
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Assessee Lawyers: SURESH MUTHUKRISHNAN
• Keywords: Transfer pricing; International transaction; Bad and doubtful debts; Royalty expenses; Related party transaction
• Section: 144; 143(3); 10B

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No.2258/Bang/2024 Assessment year : 2021-22 Netradyne Technology India Pvt. Limited, Unit 102, Sy.No.12/1 & 13/1A, HM Tech Park, Wing 2 Block, Whitefield Road, Pattandur Agrahara Village, K.R. Puram Hobli, Bangalore – 560 066. PAN: AAFCN 0712L Vs. The Income Tax Officer, Ward 5(1)(1), Bengaluru. APPELLANT RESPONDENT Appellant by : Shri Suresh Muthukrishnan, AR Respondent by : Dr. Divya K J, CIT(DR)(ITAT), Bengaluru. Date of hearing : 15.07.2025 Date of Pronouncement : 10.09.2025 O R D E R Per Prashant Maharishi, Vice President 1. This appeal is filed by Netradyne Technology India Private Limited (the assessee/appellant) for the assessment year 2021-22 against the assessment order passed by the Assessment Unit, Income Tax Department [ the ld. AO ] u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of Printed from counselvise.com ITA No.2258/Bang/2024 Page 2 of 18 the Income Tax Act, 1961 [the Act] assessing total income of the assessee at Rs.3,70,06,417/- wherein addition of Rs.3,64,31,097/- is made on account of arm’s length price [ALP] of the international transactions included in the draft assessment order passed u/s 144 C (1) of the Act dated 10.11.2023 made by the ld. Transfer pricing officer [ the ld. TPO] per Transfer pricing order u/s. 92CA(3) of the Act proposing the above adjustment and pursuant to the direction of the ld. Dispute Resolution Panel-II, Bangalore [ld. DRP] dated 28.8.2024, the above adjustment was retained. Thus, assessee is aggrieved with the above addition and is in appeal before us. 2. The assessee was incorporated on 4.11.2015 being a subsidiary of Netradyne Inc. USA engaged as a development centre based in Bangalore providing software development services to its US parent. It filed its return of income on 10.2.2022 declaring total income of Rs.5,75,320/-. 3. Assessee has two different segments of international transactions namely, [i] Software development services and [2] software license distribution segment. As it has entered into international transactions of provision of software development services having income of Rs.37,63,49,883/- and software distribution segment of software license of Rs. 1900747/-, reference was made to the ld. TPO to determine the ALP. 4. For benchmarking software development services , In Transfer pricing Study Report [ TPSR], The assessee, selecting itself as a tested party, Printed from counselvise.com ITA No.2258/Bang/2024 Page 3 of 18 has adopted Transactional Net Margin Method [TNMM] as the Most Appropriate method, selecting Proft level indicator of NCP computing its margin at 15% choosing 'Prowess' and 'capitaline database' selected 21 comparable companies whose NCP margin is ranging from 6.48 % [35th Percentile] to 15.80 percentile [65 th percentile] having a median margin of 10.77 % concluded that the international transaction of software development service is at arm’s length. 5. In Purchase of software license for distribution segment, assessee taking itself as tested party, selected Transactional Net margin method as the most appropriate method adopting Profit level indicator of Operating profit margin of assessee at (-) 419.04% selected 4 companies whose margins ranging from (-) 0.38 % to 3.38 % having arithmetic mean of 2.01 %, stated that it is at arm’s length. 6. The ld. TPO examined the TPSR and rejected the same. He rejected the filters with respect to the availability of financials, manufacturing sales, trading sales and employee cost. The ld. TPO also found that assessee has not used the export turnover filter, persistent loss filter. Thereafter the ld. TPO proceeded to carry out search process selecting different filters. The ld. TPO also considered 21 comparables selected by the assessee, rejected most of them, except Great Software Labs Pvt. Ltd. and CG VAK Software Exports Ltd. In the new search process the TPO used Prowess Database using keywords of ‘computer software, software services and consultancy’. It reached at a set of 18 comparables and issued show cause notice. The assessee objected that Printed from counselvise.com ITA No.2258/Bang/2024 Page 4 of 18 in the TP search, Mindtree Ltd., Nihilent Ltd., Tata Elxsi Ltd., Infosys Ltd., Tata Consultancy Services Ltd. & Cybage Software Pvt. Ltd. are included whose turnover are huge compared to the assessee’s turnover and therefore they should be excluded. The TPO rejected the same stating that size of the company does not have any impact on the margin as it is a service industry. Assessee also objected to certain other inclusion. In the end, the ld. TPO selected 18 comparable companies whose margin at 35th percentile was 19.95% and 65th percentile at 32.14% resulted into median margin of 29.05%, computed ALP at Rs.42,80,87,359/- compared to the international transaction of Rs.39,35,57,009/- , added shortfall adjustment of Rs.3,45,30,350/-. 7. For software licence for distribution being royalty expenses amounting to Rs.19,00,747/- ld. TPO computed the margin of assessee at (-) 180.17%. Assessee selected 4 comparable companies in its distribution of software licence segment which was excluded by the TPO by rejecting some of the filters. The TPO carried out fresh search on Prowess Database selecting 9 comparables having 35th percentile of 9.66%, 65th percentile margin of 23.98% and median margin of 9.76%. Assessee objected the exclusion of certain companies which were rejected by the TPO and taxpayer objected regarding inclusion of certain companies. On the issue of comparability, huge turnover, brand value, lack of segmental information, etc., all these objections were rejected. Thereafter the ld. TPO reached at 9 comparable companies and determined the ALP at Rs.1,14,34,892 whereas the price paid by the assessee company was Rs.3,55,02,533 determining the shortfall of Printed from counselvise.com ITA No.2258/Bang/2024 Page 5 of 18 Rs.2,40,67,642. However the adjustment was restricted to quantum of purchases at Rs.19,00,747. 8. Based on this, the draft assessment order u/s. 144C was passed on 10.11.2023 determining total income of assessee at Rs.3,70,06,417. The assessee filed objections before the ld. DRP who passed directions on 28.8.2024 and after that the final assessment order was passed on 26.9.2024 at the total income of Rs.3,70,06,417. 9. The assessee aggrieved with the assessment order is in appeal before us. The assessee submitted revised Grounds of Appeal as under :- “1. The order of the authorities below in so far as it is against the Appellant is opposed to law, equity, weight of evidence, probabilities, facts and circumstances of the case. 2. The authorities below have erred in rejecting transfer pricing documentation (`TP documentation') prepared by the Appellant and further erred in conducting a separate benchmarking exercise without appreciating the facts and circumstances of the Appellant. 3. The authorities have erred in law and on facts of this case in computing transfer pricing adjustment under Section 92CA of the Act amounting to INR 34,530,350 in respect of the software development services segment and INR 1,900,747 for the distribution segment. 4. Without prejudice to the above, the authorities have erred in computing the adjustment in the final assessment order at INR 3,64,31,097 as against INR 3,50,27,980 being the amount of adjustment determined as per the Order \"Giving Effect on TP issues\". 5. Without prejudice to the above, the learned TPO has erred in recalculating the margins of the appellant in the final order on a suo moto basis contrary to the directions of the learned DRP, which are binding on him. Printed from counselvise.com ITA No.2258/Bang/2024 Page 6 of 18 6. The authorities have erred in law and on facts by arbitrarily applying the following filters: a) By applying threshold of 75 percent in export service income filter. b) By not rejecting companies reporting abnormal profits. c) By rejecting companies having different financial year ending (i.e., year ending other than 31 March), or the companies whose data do not fall within 12 month period. d) By not applying upper limit to the turnover filter and thereby erred in selecting companies with turnover far in excess of the Appellant. e) By rejecting companies having losses for two out of three years. f) By arbitrarily applying a modified related party transactions (`RPT') filter of RPT Income/Total Sales as well as RPT expense/ Total expense and relying on the same for the comparability analysis rather than applying the filter of RPT transaction/Sales 7. The authorities below have erred on facts and in law by introducing /retaining certain companies in the final comparable set which were functionally/qualitatively dissimilar to the Appellant. S No Name of the Company 1 Mindtree Limited 2 Net4Nuts Limited 3 Larsen and Turbo Infotech Limited (76;0 4 Nihilent Limited 5 Wipro Limited 6 Great Software Laboratory Private Limited 7 Aptus Software Labs Private Limited 8 Infosys Limited 9 Cybage Software Private Limited Printed from counselvise.com ITA No.2258/Bang/2024 Page 7 of 18 10 Tata Elxsi Limited 11 Tata Consultancy Service Limited 12 Consilient Technologies Private Limited 8. The authorities below have erred on facts and in law by rejecting certain companies in the final comparable set which were functionally/qualitatively similar to the Appellant and hence ought to have been included in the final list of comparables; S.No. Name of the company 1 Infomile Technologies Limited 2 Harbinger Systems Private Limited 3 Rheal Systems Private Limited 4 Toxyl Technologies Private Limited 5 Agnicient Technologies Private Limited 6 Isummation Technologies Private Limited 9. That the authorities have erred in computation of operating margins of comparables due to incorrect classification of operating and non-operating income/expenses such as Bad debts written off, Provision for doubtful debts and rates and taxes as non-operating in nature. 10. That the learned authorities erred in not granting a working capital adjustment, despite significant differences in receivables, payables, and inventory levels between the Appellant and the selected comparables, thereby impacting the profitability margins. 11. That the learned authorities failed to provide a risk adjustment, ignoring the fact that e Appellant operates as a low-risk captive service provider, while the comparables bear full entrepreneurial risks. 12. Without prejudice to the above, the learned authorities below have erred in disregarding the commercial rationale for the loss in the distribution segment and made an adjustment for the purchase of software licenses from the Associated Enterprise (AE). 13. That the Appellant reserves the right to add, amend, alter or withdraw any of the above grounds at the time of hearing.” Printed from counselvise.com ITA No.2258/Bang/2024 Page 8 of 18 10. The ld AR did not press ground no 1 to 5, 9 and 11 to 13. Therefore, those are dismissed. 11. Pressing Ground no 6 & 7 ld AR submitted that in the software development segment, the assessee has objected to inclusion of Mindtree Ltd. having turnover of Rs.9767 crores, L&T Infotech Ltd. that have turnover of Rs.11,562 crores, Wipro Ltd. that have turnover of 50,299 crores, Infosys Ltd. that have turnover of 85,912 crores, Tata Elxsi Ltd. that have turnover of 18,260 crores and Tata Consultancy Services Ltd. that has turnover of 1,35,963 crores. It was the submission that these companies have huge turnover, possess huge brand value and therefore they are not comparable with the assessee company. The ld. AR submitted that assessee is a captive service provider receiving remuneration of 15% on its cost. Therefore, such companies that have huge turnover are not comparable with the margin of the assessee. 12. Objecting to inclusion of Net4Nuts Ltd., he submitted that this company is functionally dissimilar as it is engaged in diversified businesses. He further stated that in this company margin abnormal fluctuations are noticed and does not have segmental data. The ld. DRP wrongly rejected this argument holding that this company is engaged in software development and a consulting company. The relevant extract of annual accounts was also shown; however, same was not excluded. Printed from counselvise.com ITA No.2258/Bang/2024 Page 9 of 18 13. The assessee also as per ground No.8 submitted that certain companies were in assessee’s TPSR and comparability analysis which should have been included by the TPO, but the same were not included as the same were not part of search matrix of the TPO. 14. The ld. CIT (DR) submitted that regarding high turnover companies, the ld. TPO and the ld. DRP have given detailed reasons that in the services segment, higher turnover does not impact the margins of the companies. Their empirical data and studies given by the TPO & DRP showing yearwise turnover of various companies and their margins which clearly show that higher turnover does not impact the margin of the companies. Therefore, there is no reason that the companies with higher turnover should be excluded. 15. With respect to exclusion of Net4Nuts Ltd. & Consilient Technologies Pvt. Ltd., it was submitted that the DRP & TPO have given detailed reasoning for not including the above companies. 16. We have carefully considered the rival contentions and perused the orders of the ld. lower authorities. 17. We have carefully considered the rival contentions and perused the orders of the ld. lower authorities. Ground No.6 of the appeal is with respect to the arguments on the principal and ground No.7 is on the fact of each comparable. We have considered the argument of the assessee that turnover of the assessee of Software Development Services segment is merely Rs.39.35 crores. It is being compared with Printed from counselvise.com ITA No.2258/Bang/2024 Page 10 of 18 companies viz., Mindtree Ltd. which has turnover of 7697 crores, L&T Infotech Ltd. with turnover of Rs.11562 crores, Wipro Ltd. with turnover of Rs.50,299 crores, Infosys Ltd. having turnover of Rs.85,912 crores, Tata Elxsi Ltd. having turnover of Rs.1826 crores & Tata Consultancy Services with turnover of Rs.1,35,963 crores. 18. We find that due to the huge turnover of the comparable companies compared to the miniscule turnover of the assessee company in Software Development Services segment, those are not comparable at all. 19. It is undisputed that lower turnover filter of Rs 1 Crore is accepted by assessee as well as the learned transfer pricing officer to remove insignificant companies from comparability analysis. Therefore the issues is whether upper turnover filter should also be applied for comparability analysis or not. If higher and lower turnover filter is applied, it truncates large number of comparables, by eliminating comparables which have fairly large turnover compared to the tested entity. Naturally, large turnover companies have economies of scale compared to lower turnover entity. 20. Para number 3.43 in OECD Guidelines on Transfer Pricing (2022) says that in practice, both quantitative and qualitative criteria are used to include or reject potential comparables. Examples of qualitative criteria are found in product portfolios and business strategies. The most commonly observed quantitative criteria are Size criteria in terms of Sales, Assets or Number of Employees. The size of the transaction in Printed from counselvise.com ITA No.2258/Bang/2024 Page 11 of 18 absolute value or in proportion to the activities of the parties might affect the relative competitive positions of the buyer and seller and therefore comparability. Naturally higher turnover multiple times also shows that comparable company has higher market share compared to the tested entity. Naturally, higher market share gives freedom of selling larger volumes even at strained margins. The various studies carried out by NASSCOM and Dun Bradstreet also supports it. Though such studies have compartmentalised turnover filter of Rs. 1-200 hundred crores. Naturally in transfer pricing analysis lower turnover filter and upper turnover filter cannot be fixed and how to adopt the same depends upon the facts of each case looking at the turnover of the tested entity. In fact, the purpose of applying a filter is to have a manageable level of independent business concern having broadly similar level of turnover, intangibles, employees, and other assets. Guidance note issued by ICAI also advocates the same reasoning for adopting turnover filter. 21. In fact, the simplest way of explaining what an arm's-length price is how independent parties price a particular transaction therefore that is how related parties should also price it. To arrive at such an arm's- length price, economies of scale should also be similar/ comparable. Therefore, the upper turnover filter is necessarily required to be employed for better determination of arm's-length price. Honourable Bombay High Court in case of Pentair Water India (P.) Ltd. vs. Additional Commissioner of Income-tax, Goa [2014] 47 taxmann.com 132 (Panaji)/[2014] 164 TTJ 502 (Panaji)[23-05-2014] has also Printed from counselvise.com ITA No.2258/Bang/2024 Page 12 of 18 accepted the fact that if the turnover of the comparable is multiple times compared to the turnover of the tested entity, such comparable company should be excluded from comparability analysis. 22. We also direct to exclude the above comparable selected by the ld TPO for one more reason. All these companies are a part of renowned conglomerate and has huge brand value in the market of ITes / software development. These brands do have an added advantage in gaining new clients, extracting / mining new work from existing clients and larger pitch before public and Private sector. This is due to the intangible [whether recorded in books or not] of these brands. Thus, this makes a lot of different in asset size of the comparable with a captive service provider working on cost plus basis of remuneration. 23. Therefore, respectfully following the decision of the coordinate bench in assessee's own case in earlier year, we direct the learned transfer pricing officer to remove all these above companies from comparability analysis. In view of this, we direct the ld. AO to exclude the above comparables. 24. With respect to the objection of the assessee of inclusion of Net4Nuts Ltd., the assessee challenged the same before the ld. lower authorities that it is functionally dissimilar as it is engaged in the diversified business, it has abnormal fluctuation in the profit and therefore it should be excluded. The ld. lower authorities did not consider the objection of the assessee. We have carefully perused Para 14 of the DRP direction wherein it is stated that this company is engaged Printed from counselvise.com ITA No.2258/Bang/2024 Page 13 of 18 primarily in Software Development Services segment and consulting company offering a variety of ICT related services and products and it derives its 100% revenue from these activities only. When we look at the annual report of the above company, Schedule 16 shows that it is also engaged in management consultancy services over and above the Software Development Services. However, if we look at the volume, the total revenue of the comparable company is Rs.2,24,26,233 out of which Software Development Services revenue is Rs.2,26,16,233 and management consultancy fee is mere Rs.8,15,000/- which is merely 3.63% of the total revenue. Therefore, the company is predominantly in Software Development Services, derives 97% of its revenue from that segment. Therefore it is functionally comparable. The abnormal fluctuations in the margin is not the reason, unless it is specifically pointed out that there are extra-ordinary events occurring in the comparable company impacting the margins, thus it could not be reason for exclusion. Therefore, we do not find any infirmity in the order of the ld. DRP in not excluding the above company from the comparability analysis. The assessee has relied upon the decision of the coordinate Bench in PCIT v. Barclays Technology Centre Pvt. Ltd. in ITA No.1384/Bang/2015 wherein the above company is excluded. We have carefully considered the decisions relied upon before us. We find that the same is pertaining to AY 2008-09 and therefore same cannot be applied for AY 2021-22 as functional profile was not shown to be the same for these two years of this comparable. Accordingly Printed from counselvise.com ITA No.2258/Bang/2024 Page 14 of 18 reliance on the decision is not correct. Ld TPO/ DRP has rightly included this comparable. This Ground is dismissed. 25. The next comparable company objected to by the assessee is Consilient Technologies Ltd. Assessee has objected to the same stating that it is functionally dissimilar as it is engaged in diversified business, has abnormal fluctuation in the profit and segmental information is not available. The lower authorities have rejected the contention of the assessee. The ld. DRP has held that this company is rendering IT design & development services and as per corporate information available, it is engaged in the activity of software development. Before us, the ld. AR repeated the same argument. We find that the ld. DRP has given a reason that this company is engaged in the Software Development Services and is not earning revenue from sale of products which is certified by its Auditor and therefore this company is functionally comparable. Furthermore, the argument of abnormal profit was also rejected for the reason that it cannot be a reason for exclusion of any company, unless extra-ordinary event impacting the margin is shown. As this comparable company is in the single segment of Software Development Services, the argument of the assessee that it did not have segmental information is also not relevant. Therefore, according to us, there is no infirmity in the order of the ld. lower authorities for not excluding this comparable company. Accordingly ground Nos. 6 & 7 of the appeal are partly allowed. Printed from counselvise.com ITA No.2258/Bang/2024 Page 15 of 18 26. Vide ground No.8, assessee has stated that there are 6 comparable companies which are functionally and qualitatively similar to the appellant, hence should have been included in the final list of comparables. The companies challenged by the assessee is exclusion with respect to certain companies which are in the accept/reject matrix of the assessee and same have been in Search matrix of the ld. TPO and upheld by the DRP. The reason given by the DRP is that those companies did not appear in the search matrix of the TPO and therefore it cannot be now included. 27. We have considered the argument of the ld. AR and LD DR . The issue before us that when the ld TPO has computed the arm's length price of an international transactions in manner by (i) Selecting tested party , (ii) Identifying the database, (iii) search on database by applying qualitative filters of search key words relevant to the functions of the assessee (iv) Defining quantitative filters and applying them (V) Selecting set of comparables, (vi) applying various adjustments such as working capital and risk adjustments etc, (vii) thereafter determining the Arm's length price of the Transactions. Now bypassing all these steps, assessee says that some comparable companies should also be included as those are providing similar functions as of the assessee. As the TPSR of the assessee stands rejected and not opposed, now the search process and filters applied by the assessee are no more relevant. Those companies which are argued to be included are also part of the same rejected TPSR. Thus, the arguments are though TPSR is rejected but resultant companies should Printed from counselvise.com ITA No.2258/Bang/2024 Page 16 of 18 be included in comparability analysis, is bizarre and deserves to be rejected. 28. Another reason for rejection of this argument is that it is not shown to us by assessee that this companies does appear in the accept reject matrix of the ld. TPO, but those have been wrongly excluded by ld TPO. Against this, the Ld TPO and LD DRP has categorically held that those companies did not find place in search matrix of the assessee. This reason of the ld DRP and Ld TPO remains unassailed. 29. One more reason for rejecting the arguments of the ld AR is that, if one company stated to be included which favours the assessee, then there may be several other companies which are also having similar far and not in the comparable set of the ld TPO, those should also be included. Therefore, if such an argument is accepted, it will make the whole search process of the LD TPO or of the assessee useless and the determination of the ALP would be vitiated. 30. If such argument is accepted, it would be a perfect case of cherry picking and search process will lose its sanctity. We find that the TP Study Report of the assessee is rejected by the TPO and therefore each and every step, filter, etc. of the TP Study Report prepared by assessee are not now relevant. There is no objection to the whole search process employed by the ld TPO except application upper turnover filter. Thus, if in the systematic process adopted by the TPO, few comparables are included without entering the accept/reject matrix of the TPO. then it will definitely amount to cherry picking. Therefore, as Printed from counselvise.com ITA No.2258/Bang/2024 Page 17 of 18 these companies did not appear in the search matrix of the TPO, such random companies cannot be added to the data set of comparability analysis. Therefore ground No.8 of the appeal is dismissed as we do not find any infirmity in the order of the ld. TPO and direction of the ld. DRP. 31. Ground No.10 is with respect to non-granting of working capital adjustment to the assessee. The ld. TPO has dealt with this issue at para 13 wherein it was stated that assessee has not been able to demonstrate that working capital difference had impacted its profit. Assessee did not produce any analysis of whether the comparable companies have financed their working capital by own funds or borrowed funds, whether any cost has been incurred on the working capital by the comparable companies and if so how the cost of such working capital had an impact on the margins of the comparable. We find that the TPO has selected his own comparables on fresh search and therefore it is for the TPO to show that working capital of comparable companies and working capital of the assessee company which is a captive service provider are same and it does not have any impact on the margin of those comparable companies. As the comparables are selected by the TPO, the ld. TPO is bound to show that the comparable companies profit margin are not inflated due to the working capital employed by them. It is unfair on the part of the TPO to put that onus on the assessee, when he has computed the ALP. The finding must be in TPO order that no adjustment u/r 10B (1) (e) (iii) is required by showing the data and its computation mechanism. This has not been Printed from counselvise.com ITA No.2258/Bang/2024 Page 18 of 18 done by the ld. TPO. Therefore we restore the this issue back to the file of the ld. TPO to grant working capital adjustment to the assessee company in accordance with law, if available, after granting opportunity of hearing. Accordingly ground No.10 of the appeal is allowed. 32. In the result, the appeal filed by the assessee is partly allowed. Pronounced in the open court on this 10th day of September, 2025. Sd/- Sd/- ( KESHAV DUBEY ) ( PRASHANT MAHARISHI ) JUDICIAL MEMBER VICE PRESIDENT Bangalore, Dated, the 10th September 2025. /Desai S Murthy / Copy to: 1. Appellant 2. Respondent 3. Pr. CIT 4. CIT(A) 5. DR, ITAT, Bangalore. By order Assistant Registrar ITAT, Bangalore. Printed from counselvise.com "