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(3) of the Act for Rs.1,49,75,581/- towards Interest on Receivables on the basis of hypothetical and notional basis without being any material on record to show that the interest should be charged in the present case. 3.1 Erred in re-characterizing the nature of transaction from 'Receivable' to 'loan' which is not permissible u/s

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

section 92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international

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

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

section 92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international

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

section 92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international

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

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

section 92C(2) 15. Initiating the penalty proceedings u/s 271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

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

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

92C(3) of the Act were satisfied. 3. On the facts and in the circumstances of the case and in contrary to law, the Ld. TPO erred and the Hon'ble DRP further erred in upholding the action of the Ld. TPO in confirming the application/ incorrect application of the following filters: •Rejection of companies with different financial year ending

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

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

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

penalty notices u/s. 271(1)(c) and 271AAB along with Draft assessment order dated 30.12.2016, which tantamount to passing of Final Assessment Order. 2. Erred in making adjustment u/s. 92CA(3) of the Act for Rs. 4,79,143/- in respect of transaction of Corporate Guarantee provided to DCO Bank, Singapore on behalf of loan to BS Resource Pte Limited

ADAMA INDIA PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(3), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2014-15 Adama India Pvt. Ltd., Vs. Income-Tax Officer, Hyderabad. Ward – 1(3), Hyderabad. Pan – Aabcm 09294F (Appellant) (Respondent) Assessee By : Shri Raghunathan S. Revenue By : Shri Y.V.S.T. Sai Date Of Hearing : 09-04-2019 Date Of Pronouncement : 03-07-2019 O R D E R

92C(3) of the Income-tax Act, 1961 (‘the Act’) while making TP adjustments and accordingly the order passed by the ld. TPO/Ld. AO should be set aside in entirety. 5. The ld. AO, on the facts and circumstances of the case and in law, has erred in invoking section 14A of the Act read with Rule

PALRED TECHNOLOGIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

Appeal is partly allowed for statistical purposes

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahuassessment Year: 2008-09

penalty proceedings u/s 271 (1 (C) of the Act. Page 2 of 11 ITA No 581 of 2020 Palred Technologies Ltd Hyderabad The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete or modify all or any of the above grounds of appeal”. 2. We notice

IVY COMPTECH PRIVATE LIMITED,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuay : 2013-14 Ivy Comptech Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1) Hyderabad. Pan – Aaaci 8884K (Appellant) (Respondent) Assessee By: Shri Prashant Meharchandani Revenue By: Shri R. Dipak Date Of Hearing: 27/04/2021 Date Of Pronouncement: 20/07/2021

penalty proceedings u/ s 271AA and 271 BA of the Act. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” Based on the facts and circumstances of the case

PLANET ONLINE PVT.LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-16(2), HYDERABAD, HYDERABAD

In the result assessee’s appeal is partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmana.Y.2011-12

section 92C(2) of the Act. 10. Erred in confirming the disallowance of the claim of assessee company u/ s 80G of the Act amounting to Rs. 1,12,790/-. 11. Erred in confirming the disallowance of the deduction claimed by the assessee company u/ s 10AA of the Act for Rs. 61,644/-. 11.a Ought to have appreciated