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.

TRANSFER PRICING ISSUES. GROUND NO.12. Firstly, ground No.12 – Disallowance of depreciation on goodwill. This issue was already decided by us while

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.

TRANSFER PRICING ISSUES. GROUND NO.12. Firstly, ground No.12 – Disallowance of depreciation on goodwill. This issue was already decided by us while

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.

TRANSFER PRICING ISSUES. GROUND NO.12. Firstly, ground No.12 – Disallowance of depreciation on goodwill. This issue was already decided by us while

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

transfer of power from the power unit to the cement unit, and making an adjustment of INR Rs. 114,14,28,568/-. 4a. By erroneously recalculating and re-computing the market value at a rate which is contrary to the provisions of section 80IA(8) and mandates of judicial authorities. 4b. By rejecting the comparable market rate for procurement

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

transfer pricing adjustment of INR 1,95,55,466 to the international transactions relating to manufacture and sale of Wheelchairs to Associated Enterprises ("AE"). 1.3. In the facts and circumstances of the case, the Ld. DRP and Ld. AO have erred in disallowance of depreciation

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

transfer pricing adjustment of INR 1,95,55,466 to the international transactions relating to manufacture and sale of Wheelchairs to Associated Enterprises ("AE"). 1.3. In the facts and circumstances of the case, the Ld. DRP and Ld. AO have erred in disallowance of depreciation

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

transfer pricing adjustment of INR 1,95,55,466 to the international transactions relating to manufacture and sale of Wheelchairs to Associated Enterprises ("AE"). 1.3. In the facts and circumstances of the case, the Ld. DRP and Ld. AO have erred in disallowance of depreciation

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

price of specified domestic transactions and however applying the turnover filter of greater than Rs.1 crore was inappropriate. However, it was observed that the assessee has requested 1/10 to 10 times turnover filter. Based on the above said filters, the ld.CIT(A) had found that following 17 comparables have qualified for 1/10th turnover of more than 100 crores. (17 comparables

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

price of specified domestic transactions and however applying the turnover filter of greater than Rs.1 crore was inappropriate. However, it was observed that the assessee has requested 1/10 to 10 times turnover filter. Based on the above said filters, the ld.CIT(A) had found that following 17 comparables have qualified for 1/10th turnover of more than 100 crores. (17 comparables

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

price of specified domestic transactions and however applying the turnover filter of greater than Rs.1 crore was inappropriate. However, it was observed that the assessee has requested 1/10 to 10 times turnover filter. Based on the above said filters, the ld.CIT(A) had found that following 17 comparables have qualified for 1/10th turnover of more than 100 crores. (17 comparables

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD, HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

price of specified domestic transactions and however applying the turnover filter of greater than Rs.1 crore was inappropriate. However, it was observed that the assessee has requested 1/10 to 10 times turnover filter. Based on the above said filters, the ld.CIT(A) had found that following 17 comparables have qualified for 1/10th turnover of more than 100 crores. (17 comparables

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

Transfer Pricing Adjustment 2. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price ("ALP") in respect of international loans to overseas Associated Enterprises by:  Directing the Ld. A.O/TPO to adopt the LIBOR rate applicable for the year under consideration+200 basis points to arrive at ALP instead

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

Transfer Pricing Adjustment 2. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price ("ALP") in respect of international loans to overseas Associated Enterprises by:  Directing the Ld. A.O/TPO to adopt the LIBOR rate applicable for the year under consideration+200 basis points to arrive at ALP instead

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

pricing adjustment is on account of difference of opinion. 5 Gainsight Software Private Limited The Appellant craves leave to add to, alter, omit or substitute any or all of the above grounds of appeal or produce further documents at any time before or at the time of the appeal.” 3. The brief facts of the case are that, the assessee

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

Transfer Pricing Adjustment of Rs. 5,82,22,320/- to arrive at Arm's Length Price of the International transactions reported by the assessee. Accordingly, this amount is being added to the returned income of the assessee. The order of the TPO is made an annexure A to this Assessment Order. Penalty proceedings u/s 270A are initiated for under reporting

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)

Depreciation adjustment 14. Without prejudice to argument in Ground 6, the expenses disallowed under 40(a) (i) of the Act should also be excluded from the cost base of the Appellant while computing the operating margin and transfer pricing

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

Transfer Pricing Officer, however, the assessee raised objections\nagainst selection of this company before the DRP as well as before us. The grievance\nof the assessee is, the company being involved in development of products and since\nno segmental details are available in the annual report, it cannot be treated as\ncomparable. The Co-ordinate Bench in Tech Mahindra

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

Transfer Pricing Grounds: A. On disallowance of weighted deduction U/s 35(2AB): 1. The Learned DRP/Assessing Officer erred in law and on facts and circumstances of the case in not allowing weighted deduction under section 35(2AB) of the Income Tax Act, 1961 in respect of expenditure incurred in connection with Clinical Trials/ Bio-Analytical and Bio- Equivalence studies without