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

section 143(3) of the Income-tax Act, 1961 ('Act'), pursuant to the directions dated 29 June 2022 by Dispute Resolution Panel, Bangalore (DRP") u/s 144C(5) of the Act and read with order dated 11 July 2022 issued by Transfer Pricing Officer (TPO) u/s 92CA of the Act, in so far as it is prejudicial to the Appellant

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

144C(3) read with Section 144B of the Act. 4. The learned PCIT is not justified in invoking revisionary proceedings under Section 263 of the Act when the essential conditions for invoking the aforesaid section did not exist. 5. The learned PCIT has erred in law and on facts in considering the matter w.r.t claim of deduction under section 801A

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)

144C of the Act which is bad in law, arbitrary, contrary to facts, law, and circumstances of the case and liable to be quashed for the following reasons: a) Satisfaction of the JCIT was not obtained before initiating the reassessment proceedings under section 147 of the Act. b) No evidence of any new tangible material has been referred

TEK SYSTEMS GLOBAL SERVICES PRIVATE LIMITED,HYDERBAD vs. DCIT, CIRCLE-2(1), HYDERBAD

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

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.487/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2018-19) Tek Systems Global Vs. Dy. C. I. T. Services (P) Ltd, Circle 2(1) Hyderabad Hyderabad Pan:Aabcf1518Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms. K. Amulya, Ca रधजस् व द्वधरध/Revenue By:: Shri Jeevan Lal Lavidiya, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 29/05/2024 घोर्णध की तधरीख/Pronouncement: 05/07/2024 आदेश/Order

144C(13) read with section 144B of the Income-tax Act dated 29 July 2022 passed by the Assessment Unit, Income Tax Department (the Ld. AO) is perverse, erroneous on facts and bad in law to the extent detrimental to the Appellant. 2. On the facts and in the circumstances of the case and in law, the Learned Dispute Resolution

CAMBRIDGE TECHNOLOGY ENTERPRISES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.536/Hyd/2019 (निर्धारण वर्ा/Assessment Year: 2012-13) M/S Cambridge Technology Vs. Dcit Enterprises Limited Circle-1(2) Hyderabad Hyderabad [Pan :Aaacu3358G] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri Shiva Sewak, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 28/10/2024 घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.03.2019 Of The Learned Principal Commissioner Of Income Tax [Ld.Pcit], Hyderabad Pertaining To A.Y.2012-13. 2. The Brief Facts Of The Case Are That The Assessee Company, Engaged In The Business Of Rendering Software Services, Filed Its Return Of Income For The A.Y.2012-13 On 26.09.2012, Admitting Total Income Of Rs.4,05,55,380/- Under Normal Provisions Of Income Tax Act, 1961 (“The Act”) & Rs.1,47,09173/-

section 263 of the Act. The Ld.PCIT observed from the Profit & Loss account that the assessee has debited an amount of Rs.3,02,45,860/- towards impairment loss on assets. It is seen from the depreciation schedule as well as notes to account that the impairment loss on reusable components was arrived at after testing the carrying value of recorded

S & P CAPITAL IQ (INDIA) PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-3(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं / Ita-Tp No. 463/Hyd/2022 (निर्धारण वर्ा / Assessment Year: 2018-19)

section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (for short “the Act”), assessee filed this appeal. ITA-TP No. 463/Hyd/2022 2. Brief facts of the case are that the assessee is engaged in providing Information Technology Enabled Services to its Associated Enterprises (AEs). During the financial year 2016-17, assessee acquired entire shareholding

S&P CAPITAL IQ (INDIA) PRIVATE LIMITED (SUCCESSOR IN INTEREST OF SNL FINANCIAL (I) PVT LTD),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD

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

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

144C (13) of the Act was passed on 17/02/2014 making an addition of Rs. 3,05,39,702/- as per the adjustment suggested by the Ld. TPO by order dated 03/02/2014. 4. When the assessee carried the matter in appeal to the Tribunal, the Ahmedabad Bench of the Tribunal noticed that there is a conflict in the stand taken

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

In the result, the appeal of the assessee in ITA

Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)

144C(3) and 144B was passed by the Learned Assessing Officer (“Ld. AO”) on 28.06.2021, making an addition of Rs.2,26,82,071/- on account of transfer pricing adjustment. 4. Thereafter, the Ld. PCIT invoked provisions of section 263 of the Act and issued notice to the assessee on 08.03.2024. The Ld. PCIT recorded that the Ld. AO during scrutiny

ACIT., CIRCLE-5(1), HYDERABAD vs. MYLAN LABORATORIES LIMITED, HYDERABAD

In the result. appeal of the Assessee is partly allowed for statistical purposes and appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

depreciation of non-compete fee of Rs.2,22,932/- and disallowance of expenditure claimed on weighted deduction under section 35(2AB) of the Act for Rs.19,10,91,910/-. 5. The appellant company did not make application under section 144C

PROSEED INDIA LIMITED (FORMERLY GREEN FIRE AGRI COMMODITIES LIMITED ),HYDERABAD vs. ACIT, CIRCLE-2(2), , HYDERABAD

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

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

144C(13) of the Act determining the income of the assessee at Rs. 2,93,85,795/- under normal provisions of the Act and at Rs. 4,59,53,890/- under section 115 JB of the Act. 4. Assessee is, therefore, before us in this appeal seeking exclusion of the comparables, namely, M/s Accentia Technologies Limited, TCS e-Serve International

MYLAN LABORATOREIS LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

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

144C(5) of the Income Tax Act, 1961 (for short “the Act”), consequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru (“DRP”), assessee filed this appeal. ITA TP No. 1897/Hyd/2019 2. Brief facts of the case are that the assessee is a company incorporated under the Companies Act, 1956 and is engaged in the business of manufacturing active

NEOVANTAGE INNOVATION PARK PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD 16(3), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

144C(13) r.w.s. 144B of the Act, making TP additions of Rs.13,28,00,656/- on account of interest paid on NCDs and Rs.86,88,495/- on account of interest paid on CCDs and non‑TP addition of Rs.37,75,420/- on account of disallowances under section 14A of the Act and Rs.11,66,42,462/- on account of disallowance

NEOVANTAGE BIO-TECHNOLOGY PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE 5(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

144C(13) r.w.s. 144B of the Act, making TP additions of Rs.13,28,00,656/- on account of interest paid on NCDs and Rs.86,88,495/- on account of interest paid on CCDs and non‑TP addition of Rs.37,75,420/- on account of disallowances under section 14A of the Act and Rs.11,66,42,462/- on account of disallowance

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

In the result, the appeal of the assessee company is partly allowed for statistical purposes in terms of our aforesaid observations

Bench: Us:

144C of the Act, dated 29/09/2021, had observed, that as the assessee company had failed to establish any nexus between the deriving of the said income and its business operations, therefore, the subject income cannot be held as profit derived from its eligible undertaking. (ii). Rebutting the observation of the A.O., the assessee company has stated before us that

SIGNODE INDIA LIMITED,HYDERABAD vs. ACIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

144C(5) of the Act, relating to the assessment year 2016-17, and (ii) the order of the Ld. CIT(A) – 10, Hyderabad, dated 28.02.2023, passed under Section 143(3) r.w.s. 92CA(3) of the Act, relating to the assessment year 2015-16. 2. Since common issues are involved in both the appeals, these appeals were heard together

SIGNODE INDIA LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

144C(5) of the Act, relating to the assessment year 2016-17, and (ii) the order of the Ld. CIT(A) – 10, Hyderabad, dated 28.02.2023, passed under Section 143(3) r.w.s. 92CA(3) of the Act, relating to the assessment year 2015-16. 2. Since common issues are involved in both the appeals, these appeals were heard together

MYLAN LABORATORIES LTD,(FORMERLY MATRIX LABORATORIES LIMITED), HYD HYD,HYDERABAD vs. DCIT, CIRCLE-16(2), HYD, HYDERABAD

In the result, appeal of Revenue is partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

144C(3). Aggrieved by the said order assessee preferred an appeal before the CIT(A). Before the Ld.CIT(A), assessee ITA Nos. 626 & 659/Hyd/2016 :- 3 -: contested various additions and the Ld.CIT(A) allowed the appeal partially. Assessee and Revenue are in appeal before us. 3. We have heard the Ld. Counsel and Ld. CIT DR in detail and perused

DCIT, CIRCLE-16(2), HYD, HYDERABAD vs. MYLAN LABORATORIES LTD., HYD, HYDERABAD

In the result, appeal of Revenue is partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

144C(3). Aggrieved by the said order assessee preferred an appeal before the CIT(A). Before the Ld.CIT(A), assessee ITA Nos. 626 & 659/Hyd/2016 :- 3 -: contested various additions and the Ld.CIT(A) allowed the appeal partially. Assessee and Revenue are in appeal before us. 3. We have heard the Ld. Counsel and Ld. CIT DR in detail and perused