AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2026 (5) TMI 33
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.....w.s 144B of the Income- tax Act, 1961 ('the Act') in pursuance to the order of the Deputy Commissioner of Income-tax, Transfer Pricing, 2(2)(2) ('the Learned Transfer Pricing Officer' or the Learned TPO'), and the directions of the Hon'ble Dispute Resolution Panel-II, Bangalore ('Hon'ble DRP' or 'DRP'), to the extent prejudicial to the Appellant, is bad in law and is liable to be quashed. 2. On the facts and in circumstances of the case, the Learned AO erred in issuing computation sheet depicting demand payable of INR 7,41,76,950 as an annexure to the final assessment order, even though the demand notice issued by himself under section 156 of the Act indicates a Nil demand. 3. Without prejudice to the other grounds of appeal, based on the facts and in the circumstances of the present case, the final assessment order passed by the Ld. AO being passed not in conformity with the mandatory directions issued by the Ld. DRP is bad in law as per the provisions of section 144C(13) of the Act and hence liable to be quashed. 4. On the facts and circumstances of the case, the Learned AO has erred in not appreciating that ....
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....aw, the Hon'ble DRP / Learned AO / Learned TPO have erred by recharacterizing the trading of industrial robots segment as manufacturing by disregarding the actual substance of the functions performed by the segment and the detailed submission of the facts made by the Appellant before the Learned TPO. 10. On the facts and in circumstances of the case and in law, the Hon'ble DRP / Learned AO / Learned TPO have erred by applying the current year data filter thereby accepting only those companies whose data is available for FY 2019-20 in respect of the Appellant's manufacturing of AC drives and VFD Panels, trading o industrial robots and provision of software development services segments. 11. On the facts and in circumstances of the case and in law, the Hon'ble DRP / Learned AO / Learned TPO have erred by applying different accounting year filter as a comparability criterion (i.e., companies having accounting year other than March 31 or companies whose financial statements were for a period other than 12 months) in respect of the Appellant's provision of software development services segment. 12. On the facts and in circumstances of the c....
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....anies as comparable based on unreasonable comparability criteria in respect of the Appellant's manufacturing of AC drives and VFD Panels, trading of industrial robots and provision of software development services segments. 19. On the facts and in circumstances of the case and in law, the Hon'ble DRP / Learned AO / Learned TPO have erred rejecting certain companies as comparable based on unreasonable comparability criteria in respect of the Appellant's manufacturing of AC drives and VFD Panels, trading of industrial robots and provision of software development services segments. 20. On the facts and in circumstances of the case and in law, the Hon'ble DRP / Learned AO / Learned TPO have erred by wrongly computing the operating margins of Yaskawa India and some of the comparable companies considered in the TP order in respect of the Appellant's manufacturing of AC drives and VFD Panels, trading of industrial robots and provision of software development services segments 21. On the facts and in circumstances of the case and in law, the Hon'ble DRP / Learned AO / Learned TPO have erred by not making suitable adjustment to account, / d....
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....ed final assessment order for AY 2020-21 towards the transactions undertaken by the Appellant with its Associated Enterprises in Japan. It is further submitted that a resolution has been arrived at between the Competent Authorities of India and Japan on 17 December 2025 (copy of the MAP communication has been enclosed as Annexure 1) on the abovementioned transfer pricing issue raised before this Hon'ble Tribunal is the present appeal. The Appellant proposes to accept the said resolution so arrived at under the provisions of Article 25 of the India-Japan tax treaty for the transfer pricing issue pertaining to the transactions undertaken by the Appellant with its Associated Enterprises in Japan as resolved under the MAP As per Rule 44G of the Rules, orders giving effect to the MAP resolution shall be passed by the learned Assessing Officer once all the appeals are withdrawn by the Appellant on the issues so resolved under MAP. Accordingly, in line with the condition precedent, as prescribed under Rule 44G of the Rules, the Appellant hereby requests withdrawal of the grounds of appeal pertaining to the issues for which resolution has been arrived at under the MAP between ....
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....wa India Pvt Ltd., 17/A, Electronic City, Phase 1 Hosur Road, Electronic City S.O., Kammasandra, Bangalore - 560100 Madam/Sir, Sub: Communication of resolution of dispute under MAP with Japan in the case of YASKAWA Electric Corporation/Yaskawa India Pvt Ltd., for the A.Y. 2020-21 in accordance with rule 44G(6) of Income-tax Rules, 1962 - reg. Kindly refer to the subject cited above. 2. In accordance with rule 44G(6) of the Income-tax Rules, 1962 ('the Rules'), I am directed to state that the Indian and Japanese Competent Authorities (CAs) have agreed to resolve the MAP in the case of YASKAWA Electric Corporation/Yaskawa India Pvt Ltd., for the A. Y. 2020-21. 3. As per the MAP resolution agreed upon by the India and Japan Competent Authorities, the mutually agreed computation of the TP adjustments are as follows: Unit: INR (JPY) FYE 2020/3 Manufacturing of AC Drives Manufacturing of Robotics Segment Software Development Segment Total Initial TP Adjustments 90,144,190 78,512,280 27,069,050 195,725,520 TP adjustments relating to YEC 86,750,069 7....