ZUARI CEMENT LIMITED,KADAPA vs. DCIT, CIRCLE -1, KURNOOL

In the result, both the appeals preferred by the assessee are treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent Zuari Cement 249/Hyd/2021 2016-17 Dcit, Limited, Circle-1, Yerraguntla, Kurnool Kadapa District 132/Hyd/2022 2017-18 [Pan: Aaacz1270E]

disallowances made by the TPO out of various payments made to AE. Each ground has sub grounds which are more or less in the form of submissions. 11. Ld.AR submitted that TPO erred in rejecting the transfer pricing documentation as well as TNMM as most appropriate Page 10 of 17 ITA-TP Nos. 249/Hyd/2021 & 132/Hyd/2022 method

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

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)

method with OP/OC as the PLI. After considering the TP documentation and submissions, the TPO made an adjustment of Rs. 13,87,33,384/- in respect of interest on delayed receivables from AE by applying the SBI short-term 11 ADP Private Limited deposit rate and allowing a credit period of 60 days, vide order dated 30.01.2024 passed under Section

MYLAN LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result. appeal of the Assessee is partly\nallowed for statistical purposes and appeal of Revenue is\npartly allowed for statistical purposes

disallowance u/se.14A\nof the Act.\n8.\nAggrieved by the order of the learned CIT(A), the\nappellant company and the Revenue are now in appeal\nbefore the Tribunal.\n9.\nThe first issue that came-up for consideration\nfrom grounds of appeal of the appellant company is, TP\nadjustment in respect of sale of API segment and Project\nDevelopment Segment

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

TP) 104/Hyd/2022 Sanghi Industries Limited deduction U/s. 80IA in return of income, and no addition whatsoever was warranted to the total income. 3. That in the facts and circumstances of the case, the Ld. AO is not justified in making addition of downward adjustment of Rs. 154,38,00,527/- to the final assessable income instead of re-computing

ACIT., CIRCLE-5(1), HYDERABAD vs. MYLAN LABORATORIES LIMITED, HYDERABAD

In the result. appeal of the Assessee is partly allowed for statistical purposes and appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

disallowance u/se.14A of the Act. 8. Aggrieved by the order of the learned CIT(A), the appellant company and the Revenue are now in appeal before the Tribunal. 9. The first issue that came-up for consideration from grounds of appeal of the appellant company is, TP adjustment in respect of sale of API segment and Project Development Segment

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

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

disallowance u/sec.14A read with Rule 8D of I.T. Rules, 1962. 4. The appellant-company filed it’s objections against the Draft Assessment Order passed by the 10 ITA.No.111/Hyd./2022 Assessing Officer before the DRP-1, Bengaluru and challenged the various additions made by the Assessing Officer including TP adjustment as suggested by the TPO. The DRP vide

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)

method with profit level indicator of OP/OC of 17.45%. Further, the assessee has selected 14 comparables of similar nature with an OP/OC of 17.57% and claimed that, its transactions with AE are at arm's length price. The TPO, after considering relevant TP study document submitted by the assessee and also taking note of various facts, has made TP adjustment

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

TP Nos. 145 & 482/Hyd/2022) that, coming to the Income Tax Act, 1961, there is no express provision to support the contention of Revenue. On the other hand, section 80G(2)(iiihk) and (iiihl) of the Act expressly provide that such sums donated for Swatch Bharath Kosh and Clean Ganga Fund shall be the amounts other than the sums spent

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

disallowance pertaining to additional depreciation amounting to Rs. 27,19,777/- Page 3 of 18 ITA No 172 of 2023 Aurobindo Pharma Ltd despite directions by the Honourable DRP in this regard allowing the same as eligible expenditure. General 1. Any other ground that may be urged at the time of hearing with the previous approval

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Method [in short “RPM”] as MAM for trading of finished goods. The TPO noted that, the assessee company in order to benchmark it’s transactions, has selected 10 companies as comparables for trading of finished goods on the basis of search conducted in the public databases namely Prowess, Capitaline Plus. The TPO has analysed the TP document and noted that

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Method [in short “RPM”] as MAM for trading of finished goods. The TPO noted that, the assessee company in order to benchmark it’s transactions, has selected 10 companies as comparables for trading of finished goods on the basis of search conducted in the public databases namely Prowess, Capitaline Plus. The TPO has analysed the TP document and noted that

SATYAM VENTURE ENGINEERING SERVICES PRIVATE LIMITED ,SECUNDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -3(2), HYDERABAD

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

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita-Tp No. 192/Hyd/2021 (धििाारण वर्ा / Assessment Year: 2016-17) Satyam Venture Assistant Commissioner Engineering Services Vs. Of Income Tax, Private Limited, Central Circle-3(2), Secunderabad Hyderabad [Pan No. Aafcs3287D] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

method to benchmark the international transaction in respect of IT enabled Services (ITeS), second one is related to the Transfer Pricing (TP) adjustment in respect of the interest on trade receivables and the third one relates to the disallowances

BRIGHTCOM GROUP LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TP addition of Rs.2,00,990/- on account of disallowances under section 14A of the Act, Rs.18,72,836/- on account of disallowances under section 37 of the Act towards CSR expenditure, Rs.2,07,247/- on account of disallowance towards prior period expenses and Rs.38 lakhs on account of non-reconciliation of income as per profit and ITA No.1747/Hyd/2019

NEOVANTAGE BIO-TECHNOLOGY PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE 5(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TP addition of Rs.37,75,420/- on account of disallowances under section 14A of the Act and Rs.11,66,42,462/- on account of disallowance of set off of unabsorbed depreciation. Accordingly, the Ld. AO computed the total income of the assessee at Rs.12,04,17,883/-. 5. Aggrieved with the final assessment order of Ld. AO, the assessee

NEOVANTAGE INNOVATION PARK PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD 16(3), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TP addition of Rs.37,75,420/- on account of disallowances under section 14A of the Act and Rs.11,66,42,462/- on account of disallowance of set off of unabsorbed depreciation. Accordingly, the Ld. AO computed the total income of the assessee at Rs.12,04,17,883/-. 5. Aggrieved with the final assessment order of Ld. AO, the assessee

AUROBINDO PHARMA LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

disallowance of weighted deduction u/s 35(2AB) of the Act. In this regard, we have decided the appeal Page 4 of 18 ITA-TP No. 1860/Hyd/2019 of the assessee in ITA No.485/Hyd/2022 for A.Y. 2018-19 wherein we have held as under : “8. We have heard the rival contentions of the parties and perused the material available on record

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (INDIA) PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. ITO, WARD-16(3), HYDERABAD, HYDERABAD

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

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.309/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Oakton Global Technology Vs. Income Tax Officer Services Centre (India) (P) Ltd, Ward 16(3) Hyderabad Hyderabad Pan:Aaaco8824H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ravi Bhardwaj, Ca राज" व "ारा/Revenue By:: Smt. Th Vijaya Lakshmi, Dr सुनवाई की तारीख/Date Of Hearing: 10/06/2024 घोषणा की तारीख/Pronouncement: 12/06/2024 आदेश/Order

method. The assessee has computed the OP/OC at 11.87% and claimed that the transactions with its AEs are at ALP. The TPO after considering the relevant TP documents submitted by the assessee and also taken note of various facts rejected the TP analysis and has conducted fresh TP study with final set of 13 comparables with average OP/OC

M/S KANTAR GDC INDIA PVT. LTD. (FORMERLY TNS INDIA PVT LTD),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

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

Bench: Shri Mahavir Singh & Shri Manjunatha, G.आ.अपी.सं /Ita No.2261/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2013-14) M/S. Kantar Gdc India (P) Vs. Dy. C. I. T. Ltd (Formerly Tns India (P) Circle 2(2) Ltd, Hyderabad Hyderabad Pan:Aabcn2278F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Harpreet Singh Ajmani राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order

method. 5. The Assessing Officer has passed the draft assessment order u/s 143(3) r.w.s. 92CA of the I.T. Act on 26.12.2016 in pursuant to TP adjustment as suggested by the TPO and has proposed TP adjustment in respect of provision for ITES Services and management fees paid to AE. The learned Assessing Officer had also proposed addition towards trade