2025 (8) TMI 36

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....asan S, CIT-DR ORDER Per: Inturi Rama Rao, AM The captioned two appeals are filed by the assessee against the different orders of the Learned Commissioner of Income Tax (Appeals)-12, Bengaluru for the Assessment Years (AY) 2016-17 and 2018-19. 2. Since the identical facts and issues are involved in these appeals, both the appeals are clubbed, heard together and disposed of in this cons....

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....onal transactions, the AO referred the matter to the Transfer Pricing Officer (in short "TPO") for the purpose of benchmarking the international transactions. Thereafter, the TPO vide order dated 10/10/2019 passed the order U/s. 92CA(3) of the Income Tax Act, 1961 (in short "the Act") and suggested upward TP adjustment in respect of Corporate Guarantee Commission of Rs. 4,15,68,051/- paid to Olam ....

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....ition on account of upward adjustment of Transfer Pricing of Rs. 4,35,51,370/-. 6. Being aggrieved by the assessment order, an appeal was filed before the CIT(A) who vide impugned order confirmed the addition made by the AO. 7. Being aggrieved the appellant is in appeal before us in the present appeal. 8. When the appeal was called on, the Learned Counsel for the assessee submitted that t....

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....ate guarantee on the above lines. Accordingly, the appeal filed by the assessee is allowed for statistical purposes. 9. In the result, appeal of the assessee is partly allowed. 10. With respect to ITA No. 86/Coch/2025, AY 2018-19, since the facts and circumstances and the issue involved in this appeal is identical to that of the issue adjudicated by us in the foregoing paragraphs of this ord....