INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE2(1), HYDERABAD

In the result, appeal of the Assessee for the assessment year 2021-2022 is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.943 & 1359/Hyd/2024 Assessment Years 2020-2021 & 2021-2022 Indeed India Operations The Acit, Private Limited, Vs. Circle-2(1), Hyderabad – 500 081. Hyderabad. Telangana Pan Aadci5931J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Mahima Goud, Advocate राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

13) r.w.s.144B of the Income Tax Act [in short 2 ITA.Nos.943 and 1359/Hyd./2024 "the Act"], 1961, for the assessment years 2020-2021 and 2021-2022, respectively. ITA.No.943/Hyd./2024 – A.Y. 2020-2021 : 2. The has raised the following grounds of appeal : 1. “On the facts and in the circumstances of the case and in law, the Learned Transfer

SYED AHMED ZEESHANUDDIN,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2 , HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

144C(13) passed on 19.01.2024 is barred by limitation u/s 153B of the Act as the notice u/s 153C was issued on 30.03.2022 and the time limit to finalize the assessment is on or before 31.03.2023. 7. (a) The Ld.AO has grossly erred by not appreciating the fact that in the hands of the searched party no addition for this

ASRA AHMED ,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

144C(13) passed on 19.01.2024 is barred by limitation u/s 153B of the Act as the notice u/s 153C was issued on 30.03.2022 and the time limit to finalize the assessment is on or before 31.03.2023. 7. (a) The Ld.AO has grossly erred by not appreciating the fact that in the hands of the searched party no addition for this

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

13 to A.Y. 2017-18. Elaborating on his contention, the Ld. AR submitted that in the said preceding years, though the A.O. had not drawn any adverse inference regarding the claim of deduction u/s 80IB(11A) of the Act, that was raised by the chilling units on the profits derived from the transfer of milk to the processing units

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

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute

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

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute

PANDA SRINIVAS,HYDERABAD vs. ADIT (INT TAXN)-2, HYDERABAD

Bench: Us:

Section 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (for short “the Act”) dated 21.12.2024 for A.Y. 2018-19. The assessee has assailed the impugned order on the following grounds of appeal before us: 3 Panda Srinivas 4 Panda Srinivas 5 Panda Srinivas 6 Panda Srinivas 2. Succinctly stated, the A.O. based on information that the assessee

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

Bench: Us:

144C(13) r.w.s 144B of the Act, dated 25.02.2024, has carried the matter in appeal before us. 9. We have heard the Ld. Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them to drive home their

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

68,190/- only. The return of income was processed under section 143(1) of the Act wherein the CPC disallowed the claim of gratuity expenses for Rs. 5,13,01,761/- as per the provision of section 43B of the Act, thereby the CPC assessed the income of the assessee at Rs. 63,40,69,950/-. Subsequently

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, the assessee appeal is allowed

Bench: Shri Inturi Rama Rao & Shri Laliet Kumarvs. Dy. Commissioner Of M/S. Hyundai Motor India Engineering Pvt. Ltd., Income Tax, Circle Hyderabad. 2(2), Hyderabad. Pan Aabcjh7867C Appellant Respondent Appellant By : Shri H. Srinivasulu, Adv. Respondent By : Shri Yvst Sai, Cit-Dr. Date Of Hearing : 27.07.2022. Date Of Pronouncement : 29.07.2022. O R D E R Per Shri Inturi Rama Rao, A.M. : This Is An Appeal Filed By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-2, Hyderabad Dt.05.12.2019 For Assessment Year 2015-16. 2. The Assessee Raised The Following Grounds Of Appeal :

68 Taxmann.Com 246 4) JCB India Ltd. - Vs Dy. Commr. Of IT (Delhi High Court 398 ITR 189 5) Turner International India Pvt. Ltd. - Dy. Commr. Of IT (Delhi High Court) 398 ITR 177 6) Commissioner of IT Vs C-Sam (India) Pvt. Ltd. (Gujarat High Court) 398 ITR 182 7) Control Risk India Pvt. Ltd. - Vs Dy. Commr

DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD vs. BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU, YSR DIST., YSR DIST.

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

144C(13) of the Act for the AY 2009-10 by the DCIT, Central Circle-1(3), Bangalore wherein entity’s income of Rs. 491,38,96,684/- is accepted and further addition is also made. (vii) Page No.202 consists of the CIN No. of the entity viz., U13209KA2001PTC029707. 2. Kireeti Power Corporation Pvt Ltd: (i) This company/entity has invested

BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU,KADAPA vs. DCIT, CIRCLE-1(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

144C(13) of the Act for the AY 2009-10 by the DCIT, Central Circle-1(3), Bangalore wherein entity’s income of Rs. 491,38,96,684/- is accepted and further addition is also made. (vii) Page No.202 consists of the CIN No. of the entity viz., U13209KA2001PTC029707. 2. Kireeti Power Corporation Pvt Ltd: (i) This company/entity has invested

PRAKASH KANYADARA,VIJAYAWADA vs. INCOME TAX OFFICER (INT TAXN)-1, HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

13) of the Income Tax Act, 1961 (for short “the Act”) assessee filed this appeal. 2. Brief facts of the case are that the assessee is a non-resident and did not file return of income for the assessment year 2015-16. Learned Assessing Officer, however, found from the NMS data that the assessee made certain payments to non-resident

BHARATHI CEMENT CORPORATION PRIVATE LIMITED,,HYDERABAD vs. DCIT CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Bharathi Cement Corporation Vs. Deputy Commissioner Of Private Limited, Income Tax, Hyderabad. Circle – 2(1), Hyderabad. Pan : Aadcr3079G. (Appellant) (Respondent) Assessee By: Shri S. Kalyanasundaram, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.02.2023 Date Of Pronouncement: 17.02.2023

144C(13) of the Act and total income was assessed at Rs.268,67,58,223/-. 4. Aggrieved with the final assessment order dt.26.03.2022, assessee is now in appeal before us. 4 5. Before us Ld.AR for the assessee submitted that the only issue is whether the components like fixed demand charges, ToD charges, electric duty, and customer charge

INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE -(1) , HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.943 & 1359/Hyd/2024

13) r.w.s.144B of the Income Tax Act [in short "the Act"], 1961, for the assessment years 2020-2021 and 2021-2022, respectively. ITA.No.943/Hyd./2024 – A.Y. 2020-2021 : 2. The has raised the following grounds of appeal : 1. “On the facts and in the circumstances of the case and in law, the Learned Transfer Pricing Officer i.e, the Deputy Assistant

SRINIVAS SASAPU,USA vs. ADIT (INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

68 of the Act and added the same in the hands of the assessee . Accordingly, the Ld. AO passed final assessment order under Section 147 r.w.s. 144C(13

R A K CEREMICS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2014-15 R.A.K. Ceramics India Vs. The Deputy Commissioner Of Private Limited, Income Tax, P.O Box No.11, Circle 3(1), Adb Road, Samalkot, Hyderabad. Andhra Pradesh. Pin – 53340, Pan : Aaccr6424N. (Appellant) (Respondent) Assessee By: Shri Aliasagar Rampurwala, C.A. Revenue By: B. Balakrishna – Cit Dr Date Of Hearing: 01.05.2024 Date Of Pronouncement: 09.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2014-15 Arises From The Assessment Order Of The Deputy Commissioner Of Income Tax, Circle – 3(1), Hyderabad Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 254 Of The Income Tax Act Dated 28.11.2022. 2. The Grounds Raised By The Assessee Read As Under :

Sections 144C(13) and 254 of the Income Tax Act, 1961 ('the Act') to the extent prejudicial to the Appellant, is bad in law and is liable to be quashed. 2. On the facts and in the circumstances of the case and in law, Hon'ble Panel erred in upholding the action of the learned Transfer Pricing Officer

APACHE FOOTWEAR INDIA PRIVATE LIMITED,NELLORE vs. ACIT, CIRCLE-1(1), TIRUPATI

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

144C(13) of - the Income Tax Act, 1961. 8. The learned AO / DRP failed to appreciate the submission of the petitioner that the petitioner is a debt free company and has not paid any interest and the entire working capital requirements were made by internal accruals and capital contributions and hence there is no justification for charging notional interest