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

depreciation on the same. 7.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred disallowing the foreign remittance made towards R&D Services availed from Dr. Reddy's Research & Development B.V. (formerly known as Octoplus B.V.) and Support services avalled from Dr Reddy's Laboratories Inc USA under section

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

depreciation on the same. 7.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred disallowing the foreign remittance made towards R&D Services availed from Dr. Reddy's Research & Development B.V. (formerly known as Octoplus B.V.) and Support services avalled from Dr Reddy's Laboratories Inc USA under section

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

depreciation of earlier assessment years. 9. That in the facts and circumstances of the case, the Ld. AO is not justified in considering short credit of TDS to the tune of Rs. 30,211/- without assigning any reasons therefor. 10. The appellant craves leave to add, amend or alter any of the grounds during the course of hearing.” 2. Brief

SSNC FINTECH SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

10,325,863\n121,050\n11.1.\nSince, the company is functionally dissimilar it cannot be\ncompared with the assessee company for the purpose of TP adjustment.\n(iv) M/s. Infosys Limited:\n(a) From the profitability reported in the P & L Account (Page No.\n324, 349 and 357 of PB-II) it is evident that the company had\nundergone extraordinary

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

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

depreciation claimed on goodwill arising out\nof amalgamation at Rs.1371,56,42,098/-, disallowance of\ndepreciation of non-compete fee of Rs.2,22,932/- and\ndisallowance of expenditure claimed on weighted deduction\nunder section 35(2AB) of the Act for Rs.19,10,91,910/-.\n5.\nThe appellant company did not make application\nunder section 144C

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/-

depreciation schedule has to be treated as capital loss and cannot be allowed as deduction u/s 37(1) of the Act. Further, while processing the return of income, impairment loss of 3 Cambridge Technology Enterprises Limited Rs.3,02,45,860/- was added back and the request of the assessee for rectification of the same was rejected by the Assessing Officer

SITAPURAM POWER LIMITED-ERSTWHILE AMALGAMATING COMPANY (NOW AMALGAMATED COMPANY-ZUARI CEMENT LIMITED),KADAPA vs. DCIT, CIRCLE 1, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleआआआआ आआआआ आआ./ I.T.A. (Tp) No.79/Hyd/2022 (आआआआआआआआ आआआआ / Assessment Year: 2017-18) Erstwhile Amalgamating Company Vs. Deputy Commissioner Of – Sitapuram Power Limited Income Tax, Pan:Aajcs2098E Circle-1, (Now Amalgamated Company – Nellore. Zuari Cement Limited), Kadapa. Pan:Aajcs2098E (आआआआआआआआआ/ Appellant) (आआआआआआआआआआ/ Respondent) आआआआआआआआआ आआ आआ आआ/ Appellant : Adv. Shri Deepak Chopra & Nitin Narang By आआआआआआआआआआआ आआ आआ आआ / : Shri Kumar Pranav, Cit-Dr Respondent By आआआआआआ आआ आआआआआ / Date Of : 15/05/2024 Hearing आआआआआ आआ आआआआआ/Date Of : 02/07/2024 Pronouncement O R D E R

10) of the Act. 6.2. Without prejudice to the above, the Ld. AO / Ld. TPO / Hon’ble DRP has erred in law and on the facts by proposing the TP adjustment to the total income of the assessee without considering that the appellant and the related party have not claimed deductions U/s. 80IA of the Act and such an action

CORTEVA AGRISCIENCE SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

In the result, the Ground No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

10. That on the facts and the circumstances of the case and in law, the learned CIT(A) erred in confirming the learned TPO's stand of treating the provision for bad and doubtful debts as non- operating expenses for the purpose of margin computation of comparable companies as selected by learned TPO, completely ignoring the jurisdictional judicial precedents. Rejection

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

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

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)

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 of SNL Financials (India) Private

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

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

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

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

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