NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

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

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

5. Aggrieved, the assessee has filed its objections before the Dispute Resolution Panel and challenged various additions made by the A.O. towards TP adjustment in respect of interest on delayed receivables and also additions towards disallowance of CSR expenditure claimed under Section 80G of the Act. The Ld. DRP vide its directions issued under Section 144C

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

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

section 153 of the Income Tax Act. 15. The Ld. AO ought to have appreciated the fact that the time limit for the completion of assessment u/s 153 has lapsed on 31.12.2016 and hence the order u/s 143(3) rws 144C is invalid and bad-in-law. 16. The Appellant may add or alter or amend or modify or substitute

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

5) of the Act being handwritten, and not verifiable on the income-tax portal, the directions issued by the learned DRP are non-est and bad in law. 2. The leamed Assessment Unit (AU) erred in passing the assessment order under section 143(3) read with section 144C(13) read with section 144B, beyond the limitation period 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

5) of the Act being handwritten, and not verifiable on the income-tax portal, the directions issued by the learned DRP are non-est and bad in law. 2. The leamed Assessment Unit (AU) erred in passing the assessment order under section 143(3) read with section 144C(13) read with section 144B, beyond the limitation period under section

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

disallowing the relief claimed by the Appellant of INR 31,48,038 towards foreign tax credits under section 90/91 of the Act, without considering assessee's submission and documentary evidence. 19. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in disregarding Assessee's claim for additional relief

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

disallowed in the previous year.\nInvestment allowance under Section 32AD\n8. On the facts and circumstances of the case and in law, the Id. AO,\nunder the direction of the Hon'ble DRP, erred in not appreciating\nthat the Appellant ought to be granted investment allowance as per\nSection 32AD of the Act.\nInitiation of penalty under Section 270A

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, 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.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

EPAM SYSTEMS INDIA PRIVATE 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.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

SGD PHARMA INDIA PRIVATE LIMITED, ,MAHABUBNAGAR vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee in ITA\nNo

disallowing expenses amounting to INR 20,32,596\nunder Section 43B of the Act despite the specific direction of the Ld. Panel to allow the same.\n7.\nOn the facts and in the circumstances of the case and in law, the Ld. AO erred in initiating the\npenalty proceedings under section 270A of the Act\nThe Appellant craves leave

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

disallowance of Rs. 5,13,01,761/- for gratuity under section 43B of the Act was made in the intimation under section 143(1) of the Act and was not a variation proposed by the AO in the draft assessment order passed under section 144C

PRASANTH NANDANURU,HYDERABAD vs. ITO, (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

144C(13) 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. 2. Assessee is an individual. He was an employee of Wells Fargo (EGS) India Pvt. Ltd (“Wells India”) and was sent on short-term assignment to ITA-IT No. 369/Hyd/2022 Wells Fargo

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

5) of the Act on 28.09.2023. Pursuant thereto, the Ld. AO passed the final assessment order under section 143(3) read with section 144C(13) of the Act on 31.10.2023, making the additions on account of Disallowance

SYED AHMED ZEESHANUDDIN,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2 , HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

section 144C(5) of the Act, dated 26/12/2023 issued by the Dispute Resolution Panel-1, Bengaluru for the assessment year 2017-18. Since, the facts are identical, for the sake of convenience, these appeals are heard together and disposed by a consolidated order. 2. The assessees filed more or less common grounds of appeal and therefore, for the sake

ASRA AHMED ,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

section 144C(5) of the Act, dated 26/12/2023 issued by the Dispute Resolution Panel-1, Bengaluru for the assessment year 2017-18. Since, the facts are identical, for the sake of convenience, these appeals are heard together and disposed by a consolidated order. 2. The assessees filed more or less common grounds of appeal and therefore, for the sake

PRITHVI INFORMATION SOLUTIONS LIMITED, HYDERABAD,HYDERABAD vs. ACIT, CIRCLE-16(2), HYDERABAD, HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

5. Ought to have followed the procedure laid down under the provisions of section 92C of the Act in the Computation of arms length price for analysing the said transaction. Addition of Rs. 4,30,29,173/- towards bad debts written off :- ITA No.47/Hyd/2017 6 6. Erred in disallowing the expenditure of bad debts written

SKYBRIDGE SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, (TP)-2 HYDERBAD, HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar(Through Virtual Mode) & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2021-22 Skybridge Solutions Vs. The Deputy Commissioner Of Private Limited, Income Tax, Hyderabad, (Transfer Pricing)-2, H.No.8-2-239/L/83-A, Hyderabad. Plot No.83/A, Mla Colony, Road No.12, Banjara Hills, Hyderabad – 500034, Telangana. Pan : Aalcs1899M. (Appellant) (Respondent) Assessee By: Shri Mahesh Raichandani, C.A. Revenue By: Ms. K. Haritha, Cit-Dr Date Of Hearing: 23.04.2024 Date Of Pronouncement: 29.04.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2021-22 Arises From The Impugned Assessment Order Passed U/S 143(3) R.W.S. 144C(3) R.W.S. 144B Of The Income Tax Act Dated 26.12.2023. 2. The Brief Facts Of The Case Are That The Assessee Is A Software Development & Services Company, Filed Its Income Tax Return For The Assessment Year 2021-22 On 09.03.2022, Declaring A Total Income Of Rs.1,06,49,030. The Return Was Processed Under Section 143(1)(A) Of The Income Tax Act On 24.08.2022. Subsequently, The Case Was Selected For Scrutiny Under Cass & A Notice Under Section 143(2) Was Issued On 28.06.2022, To Which The Assessee Responded On 15.07.2023. Thereafter, A Reference Under Section 92Ca(1) Was Made To The Transfer Pricing Officer (Tpo) To Determine The Arm'S Length Price For Transactions With Associated Enterprises. The Tpo, Through An Order Dated 31.10.2023, Directed An Upward Adjustment Of Rs.1,83,25,993 To The Assessee'S Income For The Financial Year 2020-21. Consequently, A Show Cause Notice Was Issued To The Assessee On November 9, 2023, Regarding The Proposed Adjustment, Along With A Penalty Initiation Under Section 270A.

disallowance, but again, no response was forthcoming. Consequently, the draft assessment order was passed on 22.11.2023 proposing the total income at Rs. 2,98,36,480/-. The assessee was given 30 days to either accept the proposed variation or file objections with the DRP. However, no communication was received from the assessee within the stipulated timeframe. Hence, it was assumed

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/-

section 263 of the Act. The Ld.PCIT observed from the Profit & Loss account that the assessee has debited an amount of Rs.3,02,45,860/- towards impairment loss on assets. It is seen from the depreciation schedule as well as notes to account that the impairment loss on reusable components was arrived at after testing the carrying value of recorded

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

144C(13) r.w.s. 144B of the Income Tax Act, 1961 (for short “the Act”) assessee filed these appeals. For the sake of convenience, we dispose of these appeals by this common order, taking appeal for the assessment year 2017-18 as a lead case. ITA-TP Nos. 145 & 482/Hyd/2022 2. Briefly stated relevant facts are that the name

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

144C(13) r.w.s. 144B of the Income Tax Act, 1961 (for short “the Act”) assessee filed these appeals. For the sake of convenience, we dispose of these appeals by this common order, taking appeal for the assessment year 2017-18 as a lead case. ITA-TP Nos. 145 & 482/Hyd/2022 2. Briefly stated relevant facts are that the name