CURIA INDIA PRIVATE LIMITED,TELEGANA vs. DCIT, CIRCLE 1(1), HYDERABAD

ITA 967/HYD/2024Status: DisposedITAT Hyderabad21 August 2026AY 2020-2117 pages
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What were the facts?

The assessee, engaged in R&D services, filed its return declaring Nil income. The AO made significant transfer pricing adjustments for R&D services, interest on delayed receivables, and interest on ECBs, leading to a revised total income. The assessee appealed against the final assessment order.

What did the Tribunal hold?

The Tribunal directed the exclusion of a comparable company (Aurigene) from the transfer pricing analysis for R&D services, allowing the appeal on this issue. It also directed benchmarking of interest on ECBs at LIBOR plus 3%, following its own prior decision. The issues related to the CPC's adjustments for bonus and brought forward losses were dismissed as they did not arise from the impugned assessment order and were pending before the CIT(A).

What were the issues?

Whether a comparable company met the R&D service income filter for transfer pricing. Whether interest on ECBs was correctly benchmarked. Whether issues already pending before the CIT(A) could be adjudicated by the ITAT.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 92CA(3),Section 143(1),Section 35DD,Section 43B

AI-generated summary — verify with the full judgment below

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

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 06/08/2026

Per Madhusudan Sawdia, A.M.:

This appeal is filed by M/s. Curia India Private Limited (“the assessee”), feeling aggrieved by the order passed by the Assessing Officer (“A.O”), on 30.07.2024 under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (“the Act”) for the A.Y. 2020-21. 2. The assessee has raised the following grounds of appeal:

3.

The brief facts of the case are that the assessee is a company engaged in the business of manufacturing and contract research activities in the field of medicinal chemistry. The assessee fi

The order continues below.

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