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

SHV ENERGY PRIVATE LIMITED.,HYDERABAD. vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-3(1)., HYDERABAD.

In the result, appeal of the assessee is dismissed

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

transfer pricing study report afresh. 3. Subsequently, Ld. PCIT, having gone through the assessment record proposed to revise the same by notice under section 263 of the Act on the ground that the assessment order is erroneous and prejudicial to the interest of Revenue. After hearing the assessee, by order dated 09/11/2015 the Ld. PCIT directed the learned Assessing Officer

INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. DCIT-2(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2016-17 Indeed India Operations Vs. The Deputy Commissioner Private Limited, Of Income Tax, Hyderabad. Circle – 2(1), Pan : Aadci5931J. Hyderabad. (Appellant) (Respondent) Assessee By: Shri H. Srinivasulu Revenue By: Shri Rajendra Kumar, Cit-Dr Date Of Hearing: 11.07.2022 Date Of Pronouncement: 10.08.2022

transfer pricing study namely, Evoke Technologies Limited. However, no other comparable namely Akshay Software, Sasken communication Technologies Ltd. and Intense Technologies Ltd. have not been pressed by the assessee. Accordingly, the inclusion of these three comparables are rejected. III. As mentioned herein above in ground No.6 assessee has pressed for incorrect rejection of comparable company that is functionally comparable

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

transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 1,23,24,559. 16. On the fact, and circumstances of the case and in contrary to law, the addition made by the Ld. TPO with respect to interest on outstanding receivables is untenable and be deleted since the addition has been made by computing interest

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

transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 1,23,24,559. 16. On the fact, and circumstances of the case and in contrary to law, the addition made by the Ld. TPO with respect to interest on outstanding receivables is untenable and be deleted since the addition has been made by computing interest

HIMASAGAR KRISHNA MUTHAPPAGARI,TIRUPATI vs. ITO., WARD-2(3), TIRUPATI

Bench: Us.

condonation of delay involved in filing of an appeal. 5. Succinctly stated, the assessee had filed his return of income for A.Y 2016-17 on 31.03.2018 disclosing an income of Rs.6,43,030/-. Thereafter, the original assessment was framed by the Assessing Officer vide his order passed under Section 143(3) of the Act, dated 24-12-2018, determining

ORBIS REAL ESTATE FUND I,HYDERABAD (AUTH. REP.) vs. ADIT (INTERNATIONAL TAXATION)-2 - 2, HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

condone the delay of filing of the appeal before the Honorable ITAT.” 4. Brief facts of the case are that, the assessee is a foreign company incorporated in Mauritius, filed its Return of Income (“ROI”) for the A.Y. 2020-21 declaring total income of Rs.Nil, claiming a refund of Rs.13,70,49,255/-. The case of the assessee was selected

RATNA INFRASTRUCTURE PROJECTS PRIVATE LIMITED,HYDERABAD vs. ITO, WARD-3(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2012-13 Ratna Infrastructure Projects Vs. The Income Tax Officer, Ward –3(3), Private Limited, Hyderabad. Hyderabad. Pan : Aadcr5836P. (Assessee) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 20.01.2025 Date Of Pronouncement: 12.02.2025

condone the delay in the filing of the appeal and admit the appeal filed by the assessee for adjudication. 7. The brief facts of the case are that the assessee company has filed its return of income for A.Y. 2012-13 on 01.01.2014, declaring a total income of Rs.39,84,93,420/-. A search and seizure operation

SATYAM VENTURE ENGINEERING SERVICES PRIVATE LIMITED,SECUNDERABAD vs. ACIT, HYDERABAD

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

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2010-11 Satyam Venture Vs. The Asst. Commissioner Of Engineering Services Income Tax, Private Limited, Central Circle – 3(2), Secunderabad. Hyderabad. Pan : Aafcs3287D (Appellant) (Respondent) Assessee By: Sri Ca S Subrahmanyam Revenue By: Dr. Rajendra Kumar, Cit Date Of Hearing: 23.06.2022 Date Of Pronouncement: 28.06.2022 O R D E R Per Laliet Kumar, J.M. This Appeal Is Filed By The Assessee Feeling Aggrieved By The Order Of Ld.Acit, Circle 3(2), Hyderabad Dt.30.04.2021 For The Assessment Year 2010-11 On The Following Grounds :

transfer pricing adjustment to be made for trade receivables from AEs, since the assessee did not charge any interest for trade receivables from Non-AEs also. 4. The AO / TPO / DRP erred in not considering the alternate ground of the assessee that even if interest is charged, such interest should only be at LIBOR and not SBI short term deposit

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

AZINGO SOFT SYSTEMS (INDIA) PVT.LTD., HYD,SECUNDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD

In the result, the grounds of the assessee are allowed for statistical purposes

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

delay of 1 day in filing of this appeal by the Revenue is condoned and the appeal is admitted for adjudication. 3. The assessee has raised the following grounds before the Tribunal: “1. That on the facts and circumstances of the case, the final assessment order dated 30 January 2015 passed by the Deputy Commissioner of Income-tax, Circle

DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD vs. AZINGO SOFT SYSTEMS INDIA PVT. LTD., HYD, HYDERABAD

In the result, the grounds of the assessee are allowed for statistical purposes

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

delay of 1 day in filing of this appeal by the Revenue is condoned and the appeal is admitted for adjudication. 3. The assessee has raised the following grounds before the Tribunal: “1. That on the facts and circumstances of the case, the final assessment order dated 30 January 2015 passed by the Deputy Commissioner of Income-tax, Circle

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

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

NCC LIMITED, HYDERABAD,HYDERABAD vs. ACIT, CIRCLE-1(1), HYDERABAD, 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

PRIMERA MEDICAL TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

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

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

condone the delay. We, therefore, now shall proceed to hear the appeal and decide the same on merits. 3. Brief facts of the case are that the assessee is a company, engaged in the business of providing ITeS in the area of health information services, health information management, medical coding, Revenue cycle management, data quality services, core measures, electronic medical

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

MAHUA BHARATPUR EXPRESSWAYS LIMITED (FORMERLY KNOWN AS MADHUCON AGRA- JAIPUR EXPRESSWAYS LIMITED),),HYDERABAD vs. ACIT, CIRCLE-16(2), HYDERABAD

In the result, Revenue appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.285 & 286/Hyd/2018 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15)

Transfer (BOT). The assessee filed its return of income for the year under consideration on 30/09/2013 declaring loss of Rs.55.46 crores. Page 2 of 27 ITA Nos 285 286 of 2018 and ITA No.308 of 2021 Madhucon Agra Jaipur Expressways Ltd During the scrutiny assessment, the Assessing Officer noted that an amount of Rs.38.40 crores is shown as NHAI grant