MY HOME INDUSTRIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), 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.289/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) My Home Industries Vs. Dy.Cit Private Limited, Hyderabad Circle 5(1) Pan: Aabcm9480C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 28/10/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By My Home Industries Private Limited, (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.01.2024 For The A.Y 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:

disallowance under section 14A of the Act amounting to Rs.37,33,334/-. Accordingly, the Ld. AO proposed a total addition of Rs.37,49,66,519/- in the draft assessment order. The assessee did not file any objection before the Learned Dispute Resolution Panel (“Ld. DRP”) against the draft assessment order Page

VIVIMED LABS LIMITED ,HYDERABAD vs. ACIT, CENTRAL CIRCLE-8(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2018-19 M/S. Vivimed Labs Ltd Vs. A.C.I.T. Hyderabad Central Circle 8(1) Pan:Aaacv6060A Hyderabad (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao, Ca Revenue By: Smt. K. Haritha, Dr Date Of Hearing: 18/01/2023 Date Of Pronouncement: 30/01/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.07.2022 Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(13) Of The I.T. Act Relating To A.Y.2018-19. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company Engaged In The Business Of Manufacturing Of Specialties & Medicines. It Filed Its Return Of Income For The Impugned A.Y On 31.3.2019 Admitting Total Income Of Rs.17,04,19,502/- Under The Normal Provisions Of The I.T. Act & Book Profit Of Rs.8,85,19,711/- Under Mat Provisions. The Case Of The Assessee Was Selected For Scrutiny Under Cass. Accordingly Statutory Notices U/S 143(2) & 142(1) Were Issued & Served On The Page 1 Of 17

disallowance u/s 14A and the addition of Rs.67,46,635/- being duty drawback received. The Assessing Page 2 of 17 ITA No 428 of 2022 Vivimed Labs Ltd Hyderabad Officer in the final order passed on 30.07.2022 made the above additions as sustained by the DRP and determined the total income at Rs.20,50,33,895/-. 6. Aggrieved with such

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)

92C(3) of the Act were satisfied. 3 NetCracker Technology Solutions (India) Private Limited, 4. On the facts and in the circumstances of the case and contrary to law, the Ld. AO/Ld. TPO erred in and the Hon'ble DRP further erred in upholding/confirming the action of the Ld. AO/Ld. TPO in benchmarking outstanding receivables from AE as a separate

HBL POWER SYSTEMS LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

disallowance u/s.14A as per normal provisions was based on Rule 8D which cannot be considered while computing book profits u/s.115JB. 10.Any other ground that may be urged at the time of hearing with the previous approval of the Hon'ble Member of the Dispute Resolution Panel”. :- 3 -: 3. We now advert to the first issue of Arm’s Length Price

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

disallowed the claim of deduction, inter-alia, on the ground that a claim not made in the original return filed under Section 139(1) and sought to be made for the first time in a return filed pursuant to a notice under Section 153A of the Act would not be maintainable. Further, the assessee was also found to be ineligible

CAP GEMINI TECHNOLOGY SERVICES INDIA LIMITED(FORMERLY KNOWN AS IGATE GLOBAL SOLUTION LIMITED)-M/S PATNI TELECOM SOLUTIONS PVT LTD, CHANGED NAME TO M/S.IGATE INFORMATION SERVICES PRIVATE LIMITED MERGED WITH IGATE GLOBAL SOLUTIONS LIMITED ,HYDERABAD vs. ITO, WARD - 2(1), HYDERABAD

In the result, appeal raised by the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.446/Hyd/2015 (िनधा"रण वष"/Assessment Year: 2010-11) Cap Gemini Vs. Income Tax Officer Technology Services Ward 2(1) India Ltd(Formerly Igate Hyderabad Global Solutions Ltd) Hyderabad Pan:Aacca4255G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 04/07/2024 घोषणा की तारीख/Pronouncement: 23/07/2024 आदेश/Order

disallowances and observations relating thereto made by the Assessing Officer: 1. In concluding that the sum of Rs.3,69,58,189 is to be the arm's length compensation receivable by the assessee on account of provision of software development services to its associated enterprises, Reimbursement of expenses received from the associated enterprises & interest chargeable on the amounts due from

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH PRIVATE LIMITED),HYDERABAD vs. ACIT., CIRCLE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

disallowance. 13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C

ACIT, CIRLCE-5 (1), , HYDERABAD vs. MARKET TOOLS RESEARCH PRIVATE LIMITED , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

disallowance. 13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH P. LTD.,),HYDERABAD vs. ACIT, CIRLCE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

disallowance. 13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C

ACIT., CIRCLE-5(1) , HYDERABAD vs. MARKET TOOLS & RESEARCH PRIVATE LIMITED, HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

disallowance. 13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C

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

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

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

section 92C, the arm's length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely: ii.(a)……..….. iii.(e) transactional net margin method, by which — (i) the net profit margin realized by the enterprise from an international transaction entered into with an associated

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

disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280,42,75,540/-. Page 7 of 82 5. Ground Nos.1 raised by the Revenue in ITA No.348/Hyd/2023 for A.Y. 2017-18 are general in nature and requires no adjudication. 5.1. Ground No.1 and 5 raised

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

disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280,42,75,540/-. Page 7 of 82 5. Ground Nos.1 raised by the Revenue in ITA No.348/Hyd/2023 for A.Y. 2017-18 are general in nature and requires no adjudication. 5.1. Ground No.1 and 5 raised

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

disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280,42,75,540/-. Page 7 of 82 5. Ground Nos.1 raised by the Revenue in ITA No.348/Hyd/2023 for A.Y. 2017-18 are general in nature and requires no adjudication. 5.1. Ground No.1 and 5 raised

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

disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280,42,75,540/-. Page 7 of 82 5. Ground Nos.1 raised by the Revenue in ITA No.348/Hyd/2023 for A.Y. 2017-18 are general in nature and requires no adjudication. 5.1. Ground No.1 and 5 raised

PURPLETALK INDIA PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-9(1), HYDERABAD

sections": [ "143(3)", "144C(13)", "143(3A)", "143(3B)", "92CA", "92C(3)", "92D(1)", "10B", "36(1)(va)", "2(24)(x)", "37(1)", "234A", "234B", "234C", "115JB" ], "issues": "Whether the assessee's transfer pricing study and method (TNMM) were appropriate and adequately supported by evidence; whether certain companies should be excluded from the list of comparables; and whether the disallowances

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(2), HYDERABAD

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

sections": [ "143(3)", "144C(13)", "144C(5)", "80IA", "92BA", "801A(10)", "92C(3)", "92D", "10D", "115JAA", "234A", "234B", "153" ], "issues": "The primary issues involved are the validity of the assessment order due to limitation, disallowance

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

92C of the Act relating to the 'Computation of Arms Length Price 1.7. Ought to have appreciated the fact that the assessee is following a policy of not charging interest on receivables irrespective of whether the sales are made to AE or Non-AE. Hence, considering the CUP method as well, the transactions with AE are at arm's length