HIGHRADIUS TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -2(1), HYDERABAD

Bench: Us:

house R&D projects, i.e., investment in technology IP development, especially those related to automotive, broadcast, and communication. 28. We, thus, in terms of our aforementioned observations are of the view that Tata Elxsi Ltd (supra) operates in the fields of product design, engineering, and R&D, providing solutions for automotive broadcast, healthcare sectors, and further owns intellectual property

IVY SOFTWARE DEVELOPMENT SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2(1), HYDERABAD

In the result, the ground no

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

house R and D project which is supported by technology partnerships, subscriptions and active participation in the standard and technology forums, trade shows and even go by the amount of expenditure incurred for R and D which is almost 2.75% of the total revenues of the company, whereas the assessee-company is a simple service provider

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

methods are not applicable for this transaction. The following facts were considered to determine the ALP of transaction. i) When the assessee issues corporate guarantee' on behalf of its AE, the assessee incurs the following non-monetary costs viz. opportunity cost, cost of credit rating, cost of blocked finance to meet the contingencies. Further, the provision of provision of corporate

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

methods are not applicable for this transaction. The following facts were considered to determine the ALP of transaction. i) When the assessee issues corporate guarantee' on behalf of its AE, the assessee incurs the following non-monetary costs viz. opportunity cost, cost of credit rating, cost of blocked finance to meet the contingencies. Further, the provision of provision of corporate

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

methods are not applicable for this transaction. The following facts were considered to determine the ALP of transaction. i) When the assessee issues corporate guarantee' on behalf of its AE, the assessee incurs the following non-monetary costs viz. opportunity cost, cost of credit rating, cost of blocked finance to meet the contingencies. Further, the provision of provision of corporate

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

methods are not applicable for this transaction. The following facts were considered to determine the ALP of transaction. i) When the assessee issues corporate guarantee' on behalf of its AE, the assessee incurs the following non-monetary costs viz. opportunity cost, cost of credit rating, cost of blocked finance to meet the contingencies. Further, the provision of provision of corporate

OPEN TEXT TECHNOLOGIES INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

method referred to in Accounting Standard 14. Accounting\nfor Amalgamation (AS-14).\nAll the assets and liabilities of ICIL on an after the appointed date and prior to the\neffective date have been transferred to Infosys Limited on a going concern basis. As\nICIL was a wholly-owned subsidiary of Infosys Limited, no shares have been allotted\nto the shareholders

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house, some of the products owned by the company such as digite swift ALM 3. The company earns revenue from trading of goods i.e. Rs. 197.3 cr. 4. The company operates under two segments. In this regard, software services segment, amongst others also include high-end services i.e., Media & Entertainment. 5. It has extraordinary event like amalgamation 6. Segmental details

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house, some of the products owned by the company such as digite swift ALM 3. The company earns revenue from trading of goods i.e. Rs. 197.3 cr. 4. The company operates under two segments. In this regard, software services segment, amongst others also include high-end services i.e., Media & Entertainment. 5. It has extraordinary event like amalgamation 6. Segmental details

NATCO PHARMA LIMITED,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

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

Bench: Shri K. Narasimha Chary & Shri G. Manjunatha

method. Accordingly, the trade receipts from AEs beyond credit period were proposed to treat the delayed receipts as “unsecured loans” advanced to the AEs for the period of delay. Further, the TPO called the assessee company to show cause as to why the receivables after allowing a credit period of 60 days should not be charged interest @ SBI Short Term