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

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

13, 2013 of the Ministry of Corporate affairs in respect\nof Section 133 of the Companies Act, 1961.”\n(b) The company also manufactures products such as\nelectronic boards and printer circuits by importing raw\nmaterials and holding inventory, as apparent from Page No.\n119 of the PB-II. The assessee company is not engaged into\nany activity of producing

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

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

13) and section 144B of the Act passed by the Assessing Officer, pursuant to the invalid directions passed by the ld.DRP under section 144C(5) of the Act, is illegal, thus, making the final assessment order bad in law, null and void and thus, liable to be quashed.” 3. Facts of the case, in brief, are that the assessee

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

144C(3) and 144B was passed by the Learned\nAssessing Officer (“Ld. AO”) on 28.06.2021, making an addition of\nRs.2,26,82,071/- on account of transfer pricing adjustment.\n4.\nThereafter, the Ld. PCIT invoked provisions of section 263 of\nthe Act and issued notice to the assessee on 08.03.2024. The Ld.\nPCIT recorded that the Ld. AO during scrutiny

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

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

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

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

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

144C(13) of the Act, the directions issued by the Ld. DRP are binding on the Ld. AO and therefore by not following the directions issued by the Ld. DRP, the final assessment order passed by the Ld. AO has become void and is required to be rejected. 6. On the other hand, learned DR heavily relied on the orders

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:

13. Controversy involved in the present appeal lies in a narrow compass, i.e., as to whether or not the “lease rental income”, and income from the other streams of income disclosed by the assessee company under the head “Other income” in its books of account, and reported as such in its audited financials are eligible for claim of deduction under

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

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

144C on 26.02.2020 and determined the total income of the appellant company at Rs.1446,55,55,275/-. 6. Being aggrieved by the assessment order, the appellant company preferred an appeal before the learned CIT(A) and contested all additions made by the Assessing Officer including TP adjustment as suggested by the TPO under section 92CA(3) of the Act, disallowance

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

13) r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”) in pursuance to the Directions dated 15.03.2021 of the learned Dispute Resolution Panel–1 (“DRP”), Bengaluru, passed under Section 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

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

13) r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”) in pursuance to the Directions dated 15.03.2021 of the learned Dispute Resolution Panel–1 (“DRP”), Bengaluru, passed under Section 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