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

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

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

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

method with OP/OC as the PLI. After considering the TP documentation and submissions, the learned TPO proposed total adjustment of Rs. 13,56,42,964/- comprising adjustment towards provision of software development services, provision of KPO services, remittance of ESPP contribution of employees and interest on delayed receivables, vide order dated 29.10.2023 passed under Section 92CA

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

method as well, the transactions with AE are at arm's length. 1.8. Without prejudice to the above grounds, ought to have appreciated the fact that no ALP adjustment is required to be made in a case where after reducing the "adjustment as a percentage of operating cost" still the margin of the assessee is more than comparables. ITA 1862/Hyd/2017

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

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

TP Analysis. 4.6. The Ld. AO erred in considering that the segmental results are not based on audited accounts and bifurcation of sales and cost between AE and non-AE's are not based on statutory audit. 5. ALP adjustment of Rs. 1,22,27,994/- towards interest on receivables. 5.1. The Ld. AO erred in making Arm's length