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)

2 On the facts and in the circumstances of the case, the final assessment order passed by the Ld. AO under Section 143(3) read with Section 144C(13) read with Section 144B of the Act is barred by limitation as the same is passed beyond the time limit prescribed under Section 153 of the Act and hence, the order

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

2) of 92C of the Act. Corporate tax matters 6.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in disallowing the expenditure incurred for repairs and maintenance treating the same as capital in nature without considering the fact that the same does not lead to any enduring benefit. 6.2. That

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

2) of 92C of the Act. Corporate tax matters 6.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in disallowing the expenditure incurred for repairs and maintenance treating the same as capital in nature without considering the fact that the same does not lead to any enduring benefit. 6.2. That

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:

2) of section 92C, the arm's length price in relation to an international transaction or a specified domestic transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— Page 13 of 22 ITA No 289 of 2024 My Home Industries P Ltd (i) the price charged or paid

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

Section 92C of the Act 4.5. The AO/TPO erred in re-characterizing the nature of transaction from ‘Receivable’ to ‘loan’ which is not permissible u/s. 145 of the Act. 4.6. The AO/TPO Ought to have appreciated the fact that the outstanding receivables are consequential/ closely linked to the sale of services to the AE during the normal course of business

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

2) of 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

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

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(2

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(2

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(2

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(2

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

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

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

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

disallow 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

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

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 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