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

2) of 92C of the Act. Corporate tax matters 6.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in disallowing the expenditure incurred for repairs and maintenance treating the same as capital in nature without considering the fact that the same does not lead to any enduring benefit. 6.2. That

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 :

Section 92C of the Act 4.5. The AO/TPO erred in re-characterizing the nature of transaction from ‘Receivable’ to ‘loan’ which is not permissible u/s. 145 of the Act. 4.6. The AO/TPO Ought to have appreciated the fact that the outstanding receivables are consequential/ closely linked to the sale of services to the AE during the normal course of business

ACIT., CIRCLE-5(1) , HYDERABAD vs. MARKET TOOLS & RESEARCH PRIVATE LIMITED, HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH P. LTD.,),HYDERABAD vs. ACIT, CIRLCE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction

ACIT, CIRLCE-5 (1), , HYDERABAD vs. MARKET TOOLS RESEARCH PRIVATE LIMITED , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH PRIVATE LIMITED),HYDERABAD vs. ACIT., CIRCLE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction

PURPLETALK INDIA PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-9(1), HYDERABAD

section 92C(3) of the Act, if the\nTPO finds that the price charged or paid in an international\ntransaction has not been determined in accordance with\nsecs.(1) and (2) or any information and document relating to\n16\nITA.No.193/Hyd./2021\nan international transaction have not been kept and\nmaintained by the assessee-company in accordance with\nthe provisions

INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE -2(1), HYDERABAD

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

2. On the facts and in the circumstances of the case and in law, the Ld. TPO erred and the Hon'ble DRP further erred in upholding / confirming the action of the Ld. TPO in rejecting the transfer pricing analysis/ study prepared by the Appellant and conducting fresh benchmarking, without appreciating that none of the conditions mentioned in clauses

DY. COMMISSIONER OF INCOME TAX ,(INTERNATIONAL TAXATION)-1, HYDERABAD vs. FAIR FIELD DEVELOPMENT LIMITED , CYPRUS

In the result, the appeal of Revenue in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 M/S. Fairfield Developments Vs. Dy. Commissioner Of Income Limited, Tax, Hyderabad. International Taxation – 1 Pan : Aabcf3158N Hyderabad. (Appellant) (Respondent) Ita 488/Hyd/2019 Assessment Year 2014-15 Dy. Commissioner Of Income Vs. M/S. Fairfield Developments Tax, Limited, International Taxation – 1, Hyderabad. Hyderabad. Pan : Aabcf3158N (Appellant) (Respondent) Assessee By: Shri Akshay Surana & Siddharth Surana, C.A Revenue By: Shri K.P.R.R. Murthy Date Of Hearing: 27.03.2023 Date Of Pronouncement: 25.04.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 10, Hyderabad Dated 16.01.2019 For The Assessment Year 2014-15. 2 M/S. Fairfield Developments Limited

TDS made by WRPL. However, the appellant revised the return by claiming benefit of special rate of tax @ 10% relying on Article 11(2) of the India-Cyprus Double Tax Avoidance Agreement (DTAA) and offering nil income with a claim for refund of Rs.5,47,74,900/-. 8.1 The case was referred to the Transfer Pricing Officer

FAIRFIELD DEVELOPMENT LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX ,(INTERNATIONAL TAXATION), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 M/S. Fairfield Developments Vs. Dy. Commissioner Of Income Limited, Tax, Hyderabad. International Taxation – 1 Pan : Aabcf3158N Hyderabad. (Appellant) (Respondent) Ita 488/Hyd/2019 Assessment Year 2014-15 Dy. Commissioner Of Income Vs. M/S. Fairfield Developments Tax, Limited, International Taxation – 1, Hyderabad. Hyderabad. Pan : Aabcf3158N (Appellant) (Respondent) Assessee By: Shri Akshay Surana & Siddharth Surana, C.A Revenue By: Shri K.P.R.R. Murthy Date Of Hearing: 27.03.2023 Date Of Pronouncement: 25.04.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 10, Hyderabad Dated 16.01.2019 For The Assessment Year 2014-15. 2 M/S. Fairfield Developments Limited

TDS made by WRPL. However, the appellant revised the return by claiming benefit of special rate of tax @ 10% relying on Article 11(2) of the India-Cyprus Double Tax Avoidance Agreement (DTAA) and offering nil income with a claim for refund of Rs.5,47,74,900/-. 8.1 The case was referred to the Transfer Pricing Officer

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

2. On the facts and in the circumstances of the case and in contrary to law, the Ld. TPO has erred and Hon'ble DRP further erred in in upholding/confirming the action of Ld. TPO in violating the principle of natural justice by passing the Order under section 92CA(3) of the Act dated 31 October 2019 without providing

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

2. On the facts and in the circumstances of the case and in contrary to law, the Ld. TPO has erred and Hon'ble DRP further erred in in upholding/confirming the action of Ld. TPO in violating the principle of natural justice by passing the Order under section 92CA(3) of the Act dated 31 October 2019 without providing

DCIT, CIRCLE-17(2), HYDERABAD, HYDERABAD vs. VIJAI ELECTRICALS LIMITED, HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu(Through Virtual Hearing) Dy. Commissioner Of Income Tax, Circle 17(2), Hyderabad. …..Appellant. Vs. M/S. Vijay Electricals Limited, 6-3-648/1 & 2,Rajbhavan Road, Hyderabad-500 082. …..Respondent. Pan Aaacv 7259B M/S. Vijay Electricals Limited, 6-3-648/1 & 2,Rajbhavan Road, Hyderabad-500 082. …..Appellant. Vs. Dy. Commissioner Of Income Tax, Circle 17(2), Hyderabad. …..Respondent.

TDS. 2. The Ld. CIT(A) erred in law in ignoring the decision of the Hon'ble Supreme Court in the case of Vijay Shipping Corporation & Others vs. CIT, Ahmedabad 314 ITR 309, decision of the Hon'ble Gujarat High Court I the case of CIT vs. Vijay Ship Breaking Corporation 261 ITR 113 and decision

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal of the Assessee is partly\nallowed for statistical purposes

2),\nPIN 500 034. PAN AACCS8560Q\nvs.\nHyderabad – 500 004\nTelangana.\n(Appellant)\n(Respondent)\nFor Assessee : | CA Abhiroop Bhargav\nFor Revenue: Dr. Narendra Kumar Naik, CIT-DR\nDate of Hearing : 21.08.2025\nDate of Pronouncement: 24.09.2025\nORDER\nPER VIJAY PAL RAO, V.P. :\nThe above appeal has been filed by the assessee\nagainst the Final Assessment Order of the Assessing Officer

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE1-(2), HYDERABAD vs. M/S. VPR MINING INFRASTRUCTURE PVT LTD, HYDERABAD

In the result, appeal of the Revenue is partly\nallowed

2), 7th Floor, Aaykar Bhavan,\nBasheerbagh, Hyderabad – 500 004. Telangana.\nM/s. VPR Mining Infrastructure Pvt. Ltd., 3rd Floor, Plot\nNo.1259, Lakshmi Towers, Road No.36, Jubilee Hills,\nHyderabad – 524 003.\nThe CIT(A)-11, 6th Floor, Aaykar Bhavan, Basheerbagh,\nHyderabad – 500 004. Telangana.\nThe Pr. CIT-(Central), Hyderabad.\nThe DR ITAT “B” Bench, Hyderabad.\nGuard File.\n//True Copy