NEOVANTAGE INNOVATION PARK PRIVATE LIMITED,HYDERABAD vs. ITO, WARD -16(3), HYDERABAD

ITA 1101/HYD/2026Status: DisposedITAT Hyderabad07 August 2026AY 2022-2332 pages
AI SummaryRemanded

What were the facts?

The assessee, engaged in developing life sciences parks, filed its return declaring nil income after setting off brought forward unabsorbed depreciation. The Assessing Officer (AO) made transfer pricing adjustments on interest paid on Compulsorily Convertible Debentures (CCDs) and other additions, including disallowing set-off of unabsorbed depreciation.

What did the Tribunal hold?

The Tribunal held that the issue of unabsorbed depreciation set-off requires verification of the demerger scheme and the quantum of depreciation transferable. It restored the matter to the AO for verification and determination of the eligible set-off.

What were the issues?

Whether the transfer pricing adjustment on interest paid on CCDs is justified and whether the set-off of unabsorbed depreciation is allowable based on a demerger scheme.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 92CA,Section 94B,Section 72A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘A‘ Bench, Hyderabad

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 30/07/2026

Per Madhusudan Sawdia, A.M.:

This appeal is filed by Neovantage Innovation Park Private Limited (“the assessee”) against the final assessment order dated 02.01.2026 passed by the Learned Assessing Officer (“Ld. AO”) under section 143(3) read with sections 144C(13) and 144B of the Income-tax Act, 1961 (“the Act”), pursuant to the directions issued by the Learned Dispute Resolution Panel (“Ld. DRP”) under section 144C(5) of the Act for Assessment Year 2022-23. 2. The assessee has raised the following grounds of appeal:

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The order continues below.

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