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

method.\nThe TPO had also recomputed operating cost of the\nappellant company by including depreciation on goodwill by\nholding that, depreciation on goodwill is operating in nature\nbecause, the goodwill created by the appellant company in\nits books of accounts, has an asset on acquisition of certain\ncompanies is having direct nexus with business of appellant\ncompany and, therefore

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

method. The TPO had also recomputed operating cost of the appellant company by including depreciation on goodwill by holding that, depreciation on goodwill is operating in nature because, the goodwill created by the appellant company in its books of accounts, has an asset on acquisition of certain companies is having direct nexus with business of appellant 9 ITA.Nos.663 & 708/Hyd

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

method and is also a controlled transaction. 5a. That on the facts and in the circumstances of the case, the Ld. DRP failed to appreciate the fact that the reallocation of employee benefit and other expenses to the tune of Rs. 39,62,81,129/- to power unit on the basis of turnover alone, is incorrect and unscientific

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

method in respect of the international transactions mentioned by the assessee in Form 3CEB and determine the ALP. 20. NON-TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

method in respect of the international transactions mentioned by the assessee in Form 3CEB and determine the ALP. 20. NON-TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

method in respect of the international transactions mentioned by the assessee in Form 3CEB and determine the ALP. 20. NON-TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

method in respect of the international transactions mentioned by the assessee in Form 3CEB and determine the ALP. 20. NON-TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

method in respect of the international transactions mentioned by the assessee in Form 3CEB and determine the ALP. 20. NON-TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order

BIOGENEX LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

method for benchmarking the transaction by aggregating the transactions under taken during the year as all the transactions are closed linked to each other. 4.4. ought to have appreciated that Hon'ble ITAT Hyderabad in the assessee own case vide and 519, 496/Hyd/2017 for the AY 2010-11, 2011-12 & 2012-13 has directed and sent back to Ld. AO/TPO

AUROBINDO PHARMA LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.172/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2019-20) Aurobindo Pharma Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aabca7366H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri B.G. Reddy, Advocate राज" व "ारा/Revenue By:: Smt. M Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/01/2025 घोषणा की तारीख/Pronouncement: 19/02/2025 आदेश/Order

depreciation amounting to Rs. 27,19,777/- Page 3 of 18 ITA No 172 of 2023 Aurobindo Pharma Ltd despite directions by the Honourable DRP in this regard allowing the same as eligible expenditure. General 1. Any other ground that may be urged at the time of hearing with the previous approval of the Hon'ble Tribunal.” 3. Ground Nos.1

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

methods adopted for calculating depreciation are different from asset to asset. It is observed that the Company has segmental data available for indenting services which is in the nature of business support services similar to the taxpayer. (13) Segment wise information for the year ended 31st March, 2011 : Segments have been identifiedin line with the 'Accounting standard on segment reporting

AUROBINDO PHARMA LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

method of allocation of Head office expenses/Forex Loss to SEZ Unit consistently adopted by the appellant, which has also been accepted in earlier years. 13. The Ld. DRP/AO ought to have appreciated the fact that the forex loss may also consist of loss on t import of raw materials which is also used for manufacturing and selling in domestic market

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

depreciation claimed on goodwill; addition towards disallowance u/sec.14A read with Rule 8D of I.T. Rules, 1962. 4. The appellant-company filed it’s objections against the Draft Assessment Order passed by the 10 ITA.No.111/Hyd./2022 Assessing Officer before the DRP-1, Bengaluru and challenged the various additions made by the Assessing Officer including TP adjustment as suggested

VERMEIREN INDIA REHAB PRIVATE LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

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

Bench: Shri Manjunatha G & Shri Ravish Sood

depreciation. The Ld. Assessing Officer's order does not provide any detailed justification against the judicial precedents cited. In support of his submissions, the Learned Counsel for the Assessee relied upon the following decisions : 1. M/s. Liquidators of Pursa Limited vs. CIT [1954] 25 ITR 265 (SC) 2. Multican Builders Ltd. v. CIT [2005] 278 ITR 142 (Calcutta

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

Method [in short “TNMM”] as Most Appropriate\nMethod [in short “MAM”]. The appellant-company has\ncomputed Profit Level Indicator [in short “PLI”] considering\nOperating Profit/Operating Cost [in short OP/OC] at\n18.31%. The\nappellant-company\nhas selected 18\ncomparable companies with 35th percentile at 6.26% and\n65th percentile at 17.01% with Median of 12.82% and\nclaimed that, the transactions with

OPEN TEXT TECHNOLOGIES INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

depreciation has been claimed on the\nunderdeveloped intangibles. The Tribunal further noted that company has shown\ntwo revenue streams one from operations of overseas and second from other\nincome. This company has also provided telecom engineering services distinct from\nthe services of Software Development. The company cannot be considered as\ncomparable even at segmental level because there are common expenses

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

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 of set off of unabsorbed depreciation. Accordingly, the Ld. AO computed the total income of the assessee at Rs.12,04,17,883/-. 5. Aggrieved with the final assessment order of Ld. AO, the assessee

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

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 of set off of unabsorbed depreciation. Accordingly, the Ld. AO computed the total income of the assessee at Rs.12,04,17,883/-. 5. Aggrieved with the final assessment order of Ld. AO, the assessee