SRESTA NATURAL BIOPRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.711/Hyd/2024 Assessment Year 2020-2021 Sresta Natural Bioproducts Private Limited, Hyderabad. The Dcit, Circle-3(1), Vs. Pin – 500 081. Hyderabad – 500 081. Telangana. Telangana. Pan Aahcs9571J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca P Murali Mohan Rao राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 11.12.2025 घोषणा की तारीख/Pronouncement: 19.12.2025 आदेश/Order

92B of the Act. 5.7. The Ld. AO ought to have appreciated the fact that the assessee is following a policy of not charging interest on receivables irrespective of the fact that whether the sales are made to AE or Non-AE. 5.8. The Ld. AO ought to have appreciated that the assessee did not charge any interest on advances

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

92B of the Act. 1.4. Ought to have appreciated the fact that the outstanding receivables relate to the provision of services and not in the nature of any advance/loans. These are closely linked to the provision of services and hence have to be aggregated for the purpose of economic analysis. Ought to have appreciated the fact that, the assessee

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)

92B of the Act and further erred in making transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 5,08,183. 8 ADP Private Limited b) Not appreciating that the receivables are consequential/closely linked to the principal transaction of provision of services and hence have been aggregated for determination of Arm's Length Price

SEAWAY SHIPPING & LOGISTICS LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147 of the I.T.Act and the Hon'ble DRP is not justified in holding that the reassessment proceedings are valid in law as the notice was issued after a period of 4 years without any fresh material on record. 3) It is not correct for the Assessing Officer to apply the provisions of Sec.92 of the I.T.Act when