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

ADAMA INDIA PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(3), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2014-15 Adama India Pvt. Ltd., Vs. Income-Tax Officer, Hyderabad. Ward – 1(3), Hyderabad. Pan – Aabcm 09294F (Appellant) (Respondent) Assessee By : Shri Raghunathan S. Revenue By : Shri Y.V.S.T. Sai Date Of Hearing : 09-04-2019 Date Of Pronouncement : 03-07-2019 O R D E R

method, where the transactions were so interconnected and intertwined, when an independent analysis would not give reasonably fair results" 5. In the case of AWB India Pvt. Ltd (ITA No.4454/DeI/2011), the ITAT, Delhi Bench observed as under: “23. It is also noteworthy in this regard that the TPO has nowhere disputed the Appellant's contention to the effect that

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 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,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

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

In the result assessee’s appeal stand partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

method. 2.1. Erred in not following the procedure laid down under the provisions of section 92C of the Act relating to the 'Computation of arms length price' for analyzing the said transaction. 2.2. DRP Erred in enhancing the ALP adjustment to Rs.4,61,30,226/- from Rs.3,24,48,315/- without issuing any show cause notice to the assessee

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

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

Bench: Shri Manjunatha G & Shri Ravish Sood

TP documentation maintained by the Appellant. 2:3. The AO/TPO / DRP have erred in rejecting the economic analysis and methodical search process undertaken by the Appellant to identify comparable companies providing services similar to the IT services rendered by the Appellant. 2:4. The AO/TPO/DRP have erred in undertaking a fresh search at the time of transfer pricing assessment thereby

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

HACKETT GROUP (INDIA) LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, Grounds of appeal No

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmanm/S. Hackett Group (India) Vs Dy. Commissioner Of Income Ltd, Hyderabad Tax, Circle 2(2) Pan:Aaace9813C Hyderabad (Appellant) (Respondent)

depreciation claimed. Accordingly, notices were issued to the assessee. Since the assessee had entered into international Page 1 of 16 ITA No 2039 of 2017 Hackett Group India Ltd Hyderabad. transactions, the determination of the Arms’ Length Price (ALP) of the said transaction was referred to the TPO u/s 92CA of the Act. 3. The TPO considered that the assessee

KONY IT SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2014-15 M/S. Kony It Services Vs. Deputy Commissioner Of Private Limited, Income Tax, 9Th Floor, B-6, South Tower, Circle-2(1), Divyasree Orion, Sy. Room No.514, 5Th Floor, No.66/1, Raidurgam, Rr Signature Towers, Opp. Dist., Hyderbad – 500 032. Botanical Garden, Pan: Aaeck 9066 D Kondapur, Hyderabad-84. (Appellant) (Respondent) Assessee By: Sri H. Srinivasulu & Sri Kranthi Palivela Ca, Ars Revenue By: Sri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 26/08/2019 Date Of Pronouncement: 20/11/2019

TP adjustment on interest receivables. Accordingly, the Ld. TPO reduced the enhancement of Rs. 5,74,14,856 to Rs. 5,38,20,492/-. 7. At the outset, Ld. AR submitted before us that the TNMM method adopted by the Revenue is acceptable. The Ld. AR also submitted that the DRP had excluded M/s. SQS India BFSI Limited, M/s. CIGNITI

KONY INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2014-15 M/S. Kony India Private Vs. Deputy Commissioner Of Limited, Income Tax, Sez Unit Ii, Office Level-7, Circle-2(1), Building No. Ho6, Phoenix Room No.514, 5Th Floor, Info City Private Limited, Signature Towers, Opp. Serilingampally, Hyderabad Botanical Garden, – 500 081. Kondapur, Hyderabad-84. Pan: Aadck 2294 C (Appellant) (Respondent) Assessee By: Sri H. Srinivasulu & Sri Kranthi Palivela Ca, Ars Revenue By: Sri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 26/08/2019 Date Of Pronouncement: 20/11/2019

TP adjustment on interest receivables from 2,51,31,511/- to Rs. 1,05,62,753/-. Accordingly, the Ld. TPO reduced the enhancement of Rs. 19,75,16,812/- to Rs. 16,96,77,951/-. 7. At the outset, Ld. AR submitted before us that the TNMM method adopted by the Revenue is acceptable. The Ld. AR also submitted that

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