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

ITA 389/HYD/2022Status: DisposedITAT Hyderabad15 May 2026AY 2018-1929 pages
AI SummaryPartly Allowed

What were the facts?

The assessee company appealed against the AO's order concerning transfer pricing adjustments for AY 2018-19. The appeal involved disputes over TP adjustments for contract R&D and manufacturing services, selection of comparables, and imputation of interest on receivables.

What did the Tribunal hold?

The Tribunal directed the AO/TPO to recompute the arm's length price of interest on outstanding receivables by following the precedent set in the assessee's own case for prior years. The claim for adjustment of brought forward losses was upheld based on the DRP's direction to the AO to verify the records.

What were the issues?

The primary issues were the validity of transfer pricing adjustments, the selection and rejection of comparable companies, and the correct method for imputing interest on outstanding receivables. The eligibility to claim brought forward losses after amalgamation was also a key issue.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘B’ Bench, Hyderabad

Before: Shri Manjunatha G. & Shri Ravish Sood

Hearing: 25/02/2026

PER. RAVISH SOOD, J.M: The present appeal filed by the assessee company is directed against the order passed by the Assessing Officer (for short, “AO”) under section 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 (for short, “the Act”), dated 30/06/2022 for the Assessment Year (AY) 2018-19. The assessee company has assailed the impugned order on the following grounds of appeal: “Based on the facts and circumstances of the case and in law, the Ld. Assessing Officer ("Ld. AO")/ Ld. Transfer Pricing Officer ("Ld. TPO")/ Hon'ble Dispute Resolution Panel ('Hon'ble DRP') grossly erred in -

2 Curia India Pri

The order continues below.

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