NCC LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

Appeals are dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahuappellant Respondent

delay is condoned therefore. 3. We next notice that the assessee’s identical sole substantive grievance as per the main as well as additional grounds in all these appeals challenges correctness of learned lower authorities’ action making Arm’s Length Price (ALP) adjustment(s) of Rs.26,76,17,306/-, Rs.18,77,00,000/- and Rs.21,35,60,000/-; assessment year

D. E. SHAW INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1154/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. D.E. Shaw India Pvt. Dy. Commissioner Of Income Vs. Ltd., Hyderabad. Tax, Pan:Aaacd7214J Circle 8(1), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.P. Chidambaram, Adv. रधजस् व द्वधरध/Revenue By: Ms. U. Mini Chandran, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 01/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. D E Shaw India Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Assessing Officer (“Ld. Ao”) U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act”) Dated 27.06.2024 For The A.Y. 2020-21. 2. At The Outset, It Is Seen That There Is A Delay Of 66 Days In Filing Of The Present Appeal, For Which The Assessee Has Filed Condonation Petition Explaining The Reasons For Delay In Filing Of The Appeal. As Per Record, The Appeal Was Required To Be Filed On Or Before

delay of 66 days in filing of the appeal is condoned and the appeal is admitted for adjudication on merits. The assessee has raised the following grounds of appeal : 6. ITA No.1154/Hyd/2024 4 ITA No.1154/Hyd/2024 5 7. The facts of the case are that, the assessee is a company engaged in the business of providing Software Development Services

PRITHVI INFORMATION SOLUTIONS LIMITED, HYDERABAD,HYDERABAD vs. ACIT, CIRCLE-16(2), HYDERABAD, HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

condone the delay of 623 days in filing the appeal and admit the same for adjudication on merits. 5. The assessee has raised the following grounds of appeal : “ 1. Erred in making the addition of Rs. 24,88,54,488/- as adjustment towards arms length price in respect of the international truncations entered into with associated enterprises. 2. Erred

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

condone the delay of 51\ndays in filing the appeal before the Tribunal and proceed to\nadjudicate the appeal as under.\n6.\nBriefly stated facts of the case are that, the\nassessee company is engaged in the business of mining /\nexcavation of coal, removal of over burden and execution of\n\nother related works. The company is also engaged

DST WORLDWIDE SERVICES INDIA PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD, HYDERABAD

Appeal is allowed in above terms

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

delay is condoned therefore. :- 2 -: 3. We notice at the outset that there is hardly any need for us to delve much deeper so far as the assessee’s sole substantive grievance challenging Arm’s Length Price (ALP) adjustment pertaining to interest on receivables of Rs.16,82,292/-; is concerned. We make it clear first of all that such interest