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

section 143(3) of the Income-tax Act, 1961 ('Act'), pursuant to the directions dated 29 June 2022 by Dispute Resolution Panel, Bangalore (DRP") u/s 144C(5) of the Act and read with order dated 11 July 2022 issued by Transfer Pricing Officer (TPO) u/s 92CA of the Act, in so far as it is prejudicial to the Appellant

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

section 143(3) of the Income-tax Act, 1961 ('Act'), pursuant to the directions dated 29 June 2022 by Dispute Resolution Panel, Bangalore (DRP") u/s 144C(5) of the Act and read with order dated 11 July 2022 issued by Transfer Pricing Officer (TPO) u/s 92CA of the Act, in so far as it is prejudicial to the Appellant

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

disallowance of Rs. 4,96,92,167/-, without assigning any reason therefor. 3 ITA (TP) 104/Hyd/2022 Sanghi Industries Limited 8. That in the facts and circumstances of the case, the Ld. AO is not justified in determining the tax payable including interest Rs. 60,06,68,444/- without adjusting brought forward losses and unabsorbed depreciation of earlier assessment years

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 :

3. Erred in upholding the upward adjustment of Arm’s Length Price for Rs.32,73,726/-Payment of Royalty. 3.1. The Ld. TPO/AO erred in not following the procedure laid down under the provisions of Section 92C of the Act relating to the ‘Computation of Arm’s Length Price’ 3.2. The Ld. TPO ought to appreciate the fact 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:

3)(i) and (ii) of the Rules, which is to the following effect: “10B. (1) For the purposes of sub-section (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

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) 15. Initiating the penalty proceedings

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) 15. Initiating the penalty proceedings

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) 15. Initiating the penalty proceedings

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) 15. Initiating the penalty proceedings

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

3 thereto. Therefore, he submitted that Section 153A differs from Section 147, which clearly indicates that the scheme of provision of Section 153A is different from that of Section 147. In :16: ITA Nos. 1717 to 1720/Hyd/2017 & this regard, he relied upon the following judicial precedents :  DCIT Vs. Eversmile Construction Co. (P.) Ltd. [2012] 143 TTJ 322 (Mumbai)  KNR Constructions

GSS INFOTECH LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

92C of the IT Act. 2 I.T.A. No. 2255/Hyd/17 and others M/s GSS Infotech Ltd. 2.1 The TPO, vide order dated 31/10/2016, has proposed transfer pricing adjustment of Rs. 1,66,39,383/- towards provision of ITES; Rs. 15,08,074 for shortfall on account of interest on loans given by the assessee to AE; and Rs. 3

GSS INFOTECH LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

92C of the IT Act. 2 I.T.A. No. 2255/Hyd/17 and others M/s GSS Infotech Ltd. 2.1 The TPO, vide order dated 31/10/2016, has proposed transfer pricing adjustment of Rs. 1,66,39,383/- towards provision of ITES; Rs. 15,08,074 for shortfall on account of interest on loans given by the assessee to AE; and Rs. 3

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

INFOR INDIA PRIVATE LIMITED (FORMERLY KNOWN AS INFOR GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman, Accountant Memebr Assessment Year: 2012-13 Infor (India) Pvt. Ltd., Vs. Dy. Commissioner Of (Formerly Known As Infor Income-Tax, Hyderabad. Global Solutions (India) Pvt. Ltd.), Hyderabad Pan – Aaacb6197Q Appellant Respondent Assessee By: Shri Sunil Motilala Revenue By: Shri Yvst Sai

92C of the Act. DOMESTIC TAX Disallowance of employee's contribution to Provident Fund of Rs. 20,87,189/- 19. On the facts and in the circumstances of the case and in law, the Ld. AO erred in making and the Hon'ble DRP further erred upholding 1 confirming the disallowance of Rs.20,87,189/- on account of payment

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

section 92C(3) of the I.T. Act, 1961. Hence, the TPO proposes TNMM as MAM and conducted an independent search for comparable considering the functions of the assessee, the assets employed and the risks taken and the results of the search is given in the following paras”. 9. Further, for A.Y 2020-21, out of 11 comparable companies selected

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

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

3. Erred in making an adjustment of Rs. 69,65,127/- towards arms length adjustment of receivables, without appreciating the fact that the assessee has not charged any interest on delayed payments received from both AE and Non-AE. ITA No.208/Hyd./2018 AY 2013-14 M/s Cambridge Technology Enterprises Ltd. 3.1. Erred in not appreciating the fact that the outstanding

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