SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

3 ITA (TP) 104/Hyd/2022 Sanghi Industries Limited 8. That in the facts and circumstances of the case, the Ld. AO is not justified in determining the tax payable including interest Rs. 60,06,68,444/- without adjusting brought forward losses and unabsorbed depreciation of earlier assessment years. 9. That in the facts and circumstances of the case

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

TDS on payments totaling Rs. 9,70,000/- towards Auditors' Remuneration and professional charges. Consequently, this amount was disallowed under Section 40(a)(ia) and added to the total income in the draft assessment. Subsequently, on appeal DRP upheld the said disallowance in its order dated 26.09.2014 and furthermore, the DRP directed the AO to compute income in such

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

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

TDS on payments totaling Rs. 9,70,000/- towards Auditors' Remuneration and professional charges. Consequently, this amount was disallowed under Section 40(a)(ia) and added to the total income in the draft assessment. Subsequently, on appeal DRP upheld the said disallowance in its order dated 26.09.2014 and furthermore, the DRP directed the AO to compute income in such

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

TDS on payments totaling Rs. 9,70,000/- towards Auditors' Remuneration and professional charges. Consequently, this amount was disallowed under Section 40(a)(ia) and added to the total income in the draft assessment. Subsequently, on appeal DRP upheld the said disallowance in its order dated 26.09.2014 and furthermore, the DRP directed the AO to compute income in such

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

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

TDS on payments totaling Rs. 9,70,000/- towards Auditors' Remuneration and professional charges. Consequently, this amount was disallowed under Section 40(a)(ia) and added to the total income in the draft assessment. Subsequently, on appeal DRP upheld the said disallowance in its order dated 26.09.2014 and furthermore, the DRP directed the AO to compute income in such

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

92C(3) of the Act were satisfied. :- 6 -: ITA Nos..227 & 228/Hyd/2021 ADP Pvt. Ltd., Hyd. 11. On the facts and circumstances of the case and in contrary to law, the Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming the actions of the Ld. TPO in not allowing risk adjustment in accordance with

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

92C(3) of the Act were satisfied. :- 6 -: ITA Nos..227 & 228/Hyd/2021 ADP Pvt. Ltd., Hyd. 11. On the facts and circumstances of the case and in contrary to law, the Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming the actions of the Ld. TPO in not allowing risk adjustment in accordance with

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

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

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

92C(3) of the Act are satisfied in the present case.\ne. disregarding the arm's length price ('ALP\") as determined\nby the Assessee in the Transfer Pricing (TP) documentation\nmaintained in terms of section 92D of the Act read with\nRule 100 of the Income-tax Rules, 1962 ('Rules').\nf. modifying the comparability analysis in the TP\ndocumentation

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

92C(3) of the Act were satisfied. SOFTWARE DEVELOPMENT SERVICES (SDS) SEGMENT 3. 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 incorrectly selecting the following companies as com parables while benchmarking the software development segment

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

3. Having heard learned Counsel for the parties and having perused the materials on record, we are broadly in agreement with the view of tribunal. The significant features of the assessee's case were that the assessee was mainly engaged in identifying the companies in financial distress whose products were otherwise viable and taking over or financing of such companies

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

3. Having heard learned Counsel for the parties and having perused the materials on record, we are broadly in agreement with the view of tribunal. The significant features of the assessee's case were that the assessee was mainly engaged in identifying the companies in financial distress whose products were otherwise viable and taking over or financing of such companies

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

sections": [ "147", "148", "143(3)", "153A", "142(1)", "129", "144C", "40(a)(ii)", "92C", "92B" ], "issues": "The primary issues were the appropriate interest rate for benchmarking international receivables, the treatment of interest paid on service tax and TDS

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