ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

144C(13) read with section 144B of the Act, dated 06 December 2024 is illegal and void in as much as it is barred by limitation as the order is passed beyond the time limit prescribed under section 153 of the Act and therefore the order, is liable to be set aside. Grounds relating to corporate tax: 2. Ground

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G.\Nand\Nshri Ravish Sood\Nआ.अपी.सं /Ita No.917/Hyd/2024\N(निर्धारण वर्ष/Assessment Year:2020-21)\Nshakti Hormann Private\Nlimited,\Nhyderabad.\Nvs. Dcit,\Ncircle-3(1),\Nhyderabad.\Npan: Aadcs4024Q\N(Appellant)\N(Respondent)\Nनिर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao,\Nca\Nराजस्व द्वारा / Revenue By: Ms. U. Mini Chandran,\Ncit-Dr\Nसुनवाई की तारीख /Date Of Hearing: 15/10/2025\Nघोषणा की तारीख / Date Of 19/12/2025\Npronouncement:\Nआदेश / Order\Nper. Ravish Sood, J.M:\Nthe Present Appeal Filed By The Assessee Company Is Directed\Nagainst The Final Assessment Order Passed By The Assessing Officer (For\Nshort, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The\Nincome Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The\N Assessment Year (Ay) 2020-21. The Assessee Company Has Assailed\Nthe Impugned Order Passed By The Cit(A) On The Following Grounds Of\Nappeal Before Us:\N1. On The Facts & In The Circumstances Of The Case, The Final Assessment\Norder Passed U/S 143(3) R.W.S.144C(13) Of The Act Dated 25.07.2024 By\Nthe Ao & Also The Order Passed U/S 92Ca (3) Dt 30.07.2023 By The Tpo\Nare Bad In The Eyes Of Law & Thus, Unsustainable To The Test Of Appeal.\N2.0 The Final Assessment Order Passed U/S 143(3) R.W.S.144C(13) R.W.S.144B\Nis Beyond The Time Limit Prescribed U/S 153 Of The Act.\N2.

144C(13) is invalid and bad-in-law.\n3. Erred in upholding the upward adjustment of Arm's Length Price for\nRs.28,87,492/- in respect of payment of Royalty\n3. 1. The Ld. AO erred in upholding the metho followed by the TPO for\ndetermination of \"Arms length price of Royalty payment.\n3. 2. The Ld. AO erred

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

13) r.w.s.144B of the Income Tax Act [in short "the Act"], 1961. ITA.No.490/Hyd./2022 – A.Y. 2017-2018 : 2. The assessee has raised the following grounds of appeal: “General : 1. That on the facts and circumstances of the case, the final assessment order dated 30 July 2022 (received on 30 July 2022) passed by the Assessment Unit, Income Tax Department

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

13) r.w.s.144B of the Income Tax Act [in short "the Act"], 1961. ITA.No.490/Hyd./2022 – A.Y. 2017-2018 : 2. The assessee has raised the following grounds of appeal: “General : 1. That on the facts and circumstances of the case, the final assessment order dated 30 July 2022 (received on 30 July 2022) passed by the Assessment Unit, Income Tax Department

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

144C(10) and (13) of the Income Tax Act, 1961(‘ Act’). 10.2. The Ld. AO ought to have appreciated the fact that the directions issued by the DRP are binding on AO, irrespective of fact whether the same are acceptable or not to the Department. 10.3. The Ld. A.O has wrongfully made an addition of Rs.4,60,963/-towards Provident

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

144C(13) of the Act on 31.10.2023, making the additions on account of Disallowance of interest paid under section 201(1A) of the Act of Rs.2,10,265/-, Disallowance of lead role expenditure of Rs.19,58,509/-, Disallowance of payment made to M/s. Antony Burchell of Rs. 3,08,08,089/-, Disallowance under section 44DA

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute Resolution

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute Resolution

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TDS, or self-assessment tax discrepancies. 25.1 The taxpayer is notified of any adjustments via an intimation under section 143(1) of the Act, and they are given an opportunity to respond before any demand is raised. 25.2 However, an intimation under Section 143(1) is not an assessment. It is merely a preliminary check of the return filed

KNR CONSTRUCTIONS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

144C(13)\nof the Act on 29.07.2022, making an addition of\nRs.36,77,04,171/-, thereby determining the total assessed income\nof the assessee at Rs.94,76,61,851/-.\n4. Aggrieved with the order of the Ld. AO, the assessee is\nin appeal before this Tribunal. At the outset, the Learned\nAuthorized Representative (“Ld. AR”) submitted that the solitary\nissue

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

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted the provisions of section 40(a)(ia) of the Act; and (ii) and though the assessee company had during the subject year carried out international transactions with its Associated Enterprises (AEs) of Rs.23,97,35,320/-, but the AO in the course

PRAKASH KANYADARA,VIJAYAWADA vs. INCOME TAX OFFICER (INT TAXN)-1, HYDERABAD

In the result, appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

TDS was deducted, that he duly declared this income in the return of income filed on 25/10/2021 in response to notice issued under section 148 dated 24/06/2021 admitting total income of Rs. 3,68,920/-. Assessee further submitted that the cash deposits made into the bank account are out of cash in hand brought forward from preceding previous years

SHELADIA ASSOCIATES INC,SD ROAD vs. ADIT(INT TAXN)-2, HYDERABAD

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No. 537/Hyd/2023 (धििाारण वर्ा / Assessment Year: 2021-22) Sheladia Associates Inc, Adit (Int Taxn)-2, Secunderabad Vs. Hyderabad [Pan No. Aafcs7792F] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

144C(5) of the Act. Pursuant to such directions, the learned Assessing Officer passed the final assessment order dated 31/10/2023, making addition of Rs. 72,84,429/- under section 37 of the Act, Rs. 1,60,78,394/- under section 44C of the Act and Rs. 1,03,35,005/- disallowing the bad debts claimed by the assessee. Hence, this

CYIENT LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2021-22 Cyient Limited, Vs. The Deputy Commissioner Of Income Tax, Circle 1 (1), Hyderabad. Hyderabad. Apn : Aaac14887J

144C(13) read with section 144B of the Act dated 03.10.2024 relating to A.Y.2021-22. 2 2. The grounds raised by the assessee read as under : 1) The order passed by the Ld. A.O./DRP is bad in law, illegal and non-est. 2) The Ld. TPO/DRP/A.O. has erred in not accepting the characterization of the assessee as software development provider

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

144C(13) r.w.s. 144B of the Income Tax Act, 1961 (for short “the Act”) assessee filed these appeals. For the sake of convenience, we dispose of these appeals by this common order, taking appeal for the assessment year 2017-18 as a lead case. ITA-TP Nos. 145 & 482/Hyd/2022 2. Briefly stated relevant facts are that the name

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

144C(13) r.w.s. 144B of the Income Tax Act, 1961 (for short “the Act”) assessee filed these appeals. For the sake of convenience, we dispose of these appeals by this common order, taking appeal for the assessment year 2017-18 as a lead case. ITA-TP Nos. 145 & 482/Hyd/2022 2. Briefly stated relevant facts are that the name