IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER ITA No. 3356/Bang/2018 Assessment year : 2014-15 Informatica Business Solutions Vs. The Joint Commissioner Pvt. Ltd., of Income Tax, No.66/1, Bagmane Commerz 02, Special Range 3, Bagmane Tech Park, Bangalore.

C V Raman Nagar, Bangalore – 560 093.

PAN: AABCI 0762M APPELLANT RESPONDENT Appellant by : Shri Tanmayee Rajkumar, Advocate Respondent by : Shri Shashi Saklani, CIT(DR)(ITAT), Bengaluru.

Date of hearing : 15.09.2025 Date of Pronouncement : 05.12.2025

O R D E R

Per Prashant Maharishi, Vice President

1. ITA No. 3356/Bang/2018 is filed by Informatica Business Solutions Private Limited (the assessee/appellant) for assessment year 2014 – 15 against the assessment order passed under section 143(3) r.w.s. 144C of the Income Tax Act, 1961 [the Act] dated 29/10/2018 passed by the Joint Commissioner Of Income Tax, Special Range – 3, Bangalore (the learned AO) determining the total income of the assessee at ₹

603,863,180 against the returned income of ₹ 429,874,310/–.

2. The assessee is aggrieved with the assessment order raised following grounds of appeal:-

3. The brief facts shows that assessee is a company incorporated under the provisions of the Companies Act, 1956 and a wholly owned subsidiary of Informatica Corporation. It is engaged in providing software development services, sales and marketing support services and customer support services, all are in the nature of information technology enabled services to its associated enterprises. The assessee has entered into an international transaction of software development services of ₹ 1,612,069,027/–, ITeS services for a consideration of ₹ 600,191,927/– and marketing support services for a consideration of ₹

271,230,118/–. As the assessee has entered into an international transaction, the reference was made to the learned transfer pricing officer [TPO] to determine the arm's length price of the international transactions. The ld. TPO proposed an adjustment of ₹ 214,441,168/– and accordingly the draft assessment order was passed on 11/12/2017 wherein the above transfer pricing adjustment was included. The ld. AO made a further adjustment/addition to the total income of the assessee wherein he made an addition u/s. 28 (iv) of ₹ 48,845,724/–, further disallowance was made of ₹ 150,000 u/s. 37 and further disallowance was made under section 40 (a) (iii) of ₹ 3,768,805. The total income was determined at ₹ 69,80,21,969/–.

4. The assessee filed an objection before the learned Dispute Resolution Panel – 1 (DRP) against the draft order dated 11 December 2027. The ld. DRP passed the direction on 18 September 2018 and consequently the learned TPO revised the adjustment under section 92CA with respect to the software development services to ₹ 90,299,978/–, to the IT enabled services of ₹ 20,142,320 and marketing support services of ₹ 9,840,086/–. Thus the total transfer pricing adjustment was restricted to ₹ 120,282,384/–. With respect to the other addition made by the ld. AO, the ld. DRP upheld the same. Accordingly the final assessment order was passed on 29 October 2018 determining the total income of the assessee at ₹ 603,863,180/–. In the final assessment order over and above the transfer pricing adjustment of ₹ 120,282,384/– the disallowance under section 28 (iv) of ₹ 48,845,724/–, disallowance u/s. 37 of ₹ 150,000, the disallowance for non-deduction of tax at source of ₹ 3,768,805 and further disallowance u/s. 37 of ₹ 941,962 was retained.

The assessee is aggrieved with the same and is in appeal before us.

5. During the course of hearing the assessee has filed a letter dated 12 September 2025 wherein it was stated that pursuant to the Mutual Agreement Procedure the grounds of appeal related to the transfer pricing adjustments are withdrawn. The revised grounds of appeal were also filed. These grounds are dealt with in this appeal.

6. As per groun