NEOVANTAGE BIO-TECHNOLOGY PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE 5(1), HYDERABAD

ITA 924/HYD/2024Status: DisposedITAT Hyderabad10 September 2025AY 2020-21Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MADHUSUDAN SAWDIA (Accountant Member)59 pages
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What did the Tribunal hold?

The Tribunal decided to keep a legal issue concerning the benchmarking of interest open, pending the outcome of a Supreme Court decision. For other grounds, the appeals were partly allowed for statistical purposes, with specific directions to the Assessing Officer regarding verification of demerger schemes and deletion of notional interest additions.

What were the facts?

The assessees, M/s. Neovantage Innovation Park Private Limited and M/s. Neovantage Bio-Technology Private Limited, filed appeals against the final assessment orders for AY 2020-21. The appeals involved issues related to transfer pricing adjustments on interest paid on debentures and disallowance of unabsorbed depreciation.

What were the issues?

The key issues involved transfer pricing adjustments on interest paid on debentures and the allowability of set-off of unabsorbed depreciation. Another issue concerned the addition of notional interest on interest-free advances to a subsidiary.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 92CA,Section 14A,Section 72A

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

Before: SHRI VIJAY PAL RAO & SHRI MADHUSUDAN SAWDIA

Hearing: 18/08/2025

PER MADHUSUDAN SAWDIA, A.M. : These appeals are filed by M/s. Neovantage Innovation Park Private Limited and M/s. Neovantage Bio-Technology Private Limited (“the assessees”), feeling aggrieved by the separate final assessment orders passed by the respective Learned Assessing Officer

ITA Nos.923 & 924/Hyd/2024 2

(“Ld. AO”) u/s. 143(3) r.w.s

The order continues below.

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