ORDER

PER BEENA PILLAI, JUDICIAL MEMBER

Present cross appeals are filed by assessee and revenue against the order of Ld.CIT(A)-7, Bangalore dated 19.11.2018 for A.Y. 2012-13 on following grounds of appeal.

ITA No. 584/Bang/2019 (Assessee’s Appeal)

“The grounds mentioned herein by the Appellant are without prejudice to one another.

1. That on the facts and circumstances of the case, the order passed by the learned Commissioner of Income-tax (Appeals) -7, Bangalore [`CIT(A)'], to the extent prejudicial to the Appellant is bad in law and liable to be quashed.

Grounds relating to transfer pricing matters

2. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in partially confirming the action of the learned Assessing Officer (learned AO')/ learned Transfer Pricing Officer (learned TPO') and not reversing the entire adjustment to the transfer prices of international transactions with associated enterprises of INR 151,235,075/- with respect to software development serv