SIGNODE INDIA LIMITED,HYDERABAD vs. ACIT, CIRCLE-3(1), HYDERABAD

ITA 240/HYD/2023Status: DisposedITAT Hyderabad14 November 2025AY 2015-16Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MANJUNATHA G (Accountant Member)44 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal considered the grounds of appeal relating to transfer pricing adjustments and the denial of depreciation. The judgment details the specific arguments and counter-arguments presented by both the assessee and the revenue.

What were the facts?

The assessee company filed appeals against assessment orders concerning transfer pricing adjustments and denial of depreciation. The appeals involved common issues for assessment years 2015-16 and 2016-17.

What were the issues?

Key issues include the validity of transfer pricing adjustments made by the revenue and the eligibility of the assessee for depreciation on certain assets.

Which sections of the Income-tax Act were involved?

Section 32,Section 92B,Section 143(3),Section 144C

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, HYDERABAD “B” BENCH: HYDERABAD

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G

Hearing: 25.08.2025Pronounced: 14.11.2025

Heard together (2 matters)

ITA.No.434/Hyd/2021
ITA No.240/Hyd/2023

Read from the judgment's own cause title. This page is filed under one of them.

PER MANJUNATHA G. :

These appeals have been filed by the assessee- company against (i) the Final Assessment Order dated 26.04.2021 passed by the A.O. under Section 143(3) r.w.s.

2 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”) in pursuance to the Directions dated 15.03.2021 of the learned Dispute Resolution Panel–1 (“DRP”), Bengaluru, passed under Section 144C(5) of the Act, relating to the assessment year 2016-17, and (ii) the order of the Ld. CIT(A) – 10, Hyderab

The order continues below.

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