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

68,62,731 towards interest on outstanding receivables. 2. On the facts and in the circumstances of the case and in law, the Ld. TPO erred and the Hon'ble DRP further erred in upholding/confirming the action of the Ld. TPO, in rejecting the transfer pricing analysis/study prepared by the Appellant and conducting fresh benchmarking, without appreciating that none

PRASANTH NANDANURU,HYDERABAD vs. ITO, (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal of the assessee is allowed

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

144C(13) of the Income Tax Act, 1961 (for short “the Act”), consequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru (“DRP”), assessee filed this appeal. 2. Assessee is an individual. He was an employee of Wells Fargo (EGS) India Pvt. Ltd (“Wells India”) and was sent on short-term assignment to ITA-IT No. 369/Hyd/2022 Wells Fargo

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)

5. The Ld.A.O ought to have appreciated the fact the proceedings u/s 153C shall not be initiated on the same issue as the proceedings u/s 148 has not been closed. 6. The final assessment order u/s 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

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)

5. The Ld.A.O ought to have appreciated the fact the proceedings u/s 153C shall not be initiated on the same issue as the proceedings u/s 148 has not been closed. 6. The final assessment order u/s 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

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

68 of the Act is not in accordance with law and untenable.” 19. The details of the share application money received during the relevant assessment year for Rs. 311,88,97,960/- from the five parties mentioned herein above as extracted from the written submission of the Ld. AR is not disputed. From the first remand report

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

68 of the Act is not in accordance with law and untenable.” 19. The details of the share application money received during the relevant assessment year for Rs. 311,88,97,960/- from the five parties mentioned herein above as extracted from the written submission of the Ld. AR is not disputed. From the first remand report

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 :

section 144C of the Act is null and void : 1) Zuari Cement Ltd. - VS. Asst. Commr. Of IT (AP High Court) W.P. No.5557 of 2012 8 2) Asst. Commr. Of IT Vs Zuari Cement Ltd. (SC) CC 16694/2013 3) IATA Vs Dy. Commr. Of IT & Ors. (Bombay High Court) 68 Taxmann.Com 246 4) JCB India Ltd. - Vs Dy. Commr

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

Bench: Us:

5. During the course of the assessment proceedings, the A.O. made a reference u/s 92CA of the Act to the DCIT, T.P.-1, Hyderabad, for determination of the “Arm’s Length Price” (for short, “ALP”) of the specified domestic transactions reported by the assessee company for the subject year. 6. The Transfer Pricing Officer (for short “TPO”), vide his order

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

5,13,01,761/- for gratuity under section 43B of the Act was made in the intimation under section 143(1) of the Act and was not a variation proposed by the AO in the draft assessment order passed under section 144C(1) of the Act. The learned DRP noted that the CPC determined the disallowance

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

144C of the Act on 31/03/2022 proposing an addition Rs. 1,62,16,300/-, treating the cash deposits in the assessee’s account as un-explained money under section 69 of the Act. Assessee expressed his willingness to prefer an appeal before the learned CIT(A) and, therefore, the learned Assessing Officer has to pass the final assessment order

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

68,444/- without adjusting brought forward losses and unabsorbed depreciation of earlier assessment years. 9. That in the facts and circumstances of the case, the Ld. AO is not justified in considering short credit of TDS to the tune of Rs. 30,211/- without assigning any reasons therefor. 10. The appellant craves leave to add, amend or alter

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) of the Act on 15.01.2025 assessing the total income at Rs.26,10,084/-. 5

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 for adding a notional interest of Rs.10,62,036/- to the total income and filed its objections before the Dispute Resolution Panel-1, Bengaluru. Subsequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru, the TPO, DCIT, Hyderabad issued order giving effect to directions u/s.144C of the Act. 3. During the course of assessment proceedings, it was found

VALUELABS TECHNOLOGIES,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Chandra Mohan Garg & Shri Laxmi Prasad Sahu

144C(3) of the Act by issuing lice or demand uls 156 of the Act along with Draft assessment dated 28.12.2018. which tantamount to passing of Final Assessment Order. :- 2 -: M/s Value Labs Technologies, Hyd. The ld. AO/DRP erred in disallowing provision for consultancy s for Rs.32,OO,OOO/- . 2.1 Erred in making the disallowance of Provision for consultancy charges

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

144C(13) of the Income-tax Act, 1961 (" Act"), in pursuance of the directions issued by the Dispute Resolution Panel - 1, Bengaluru ("DRP"), on the following grounds: On the facts and in the circumstances of the case and in law, the Learned AO/ learned Transfer Pricing Officer ("TPO") and the DRP has erred in: TRANSFER PRICING MATTERS- 1. Imputing interest

AUROBINDO PHARMA LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee is partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

5. The Learned DRP/AO/TPO erred in law and on facts and circumstances of the case in treating Interest on Receivables as a separate International Transactions in terms of Sec 92B of the Income Tax Act, 1961. 6. The Learned TPO/AO, in pursuance of the directions of the DRP, erred in making an addition

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

Bench: Us:

section 143(1) of the Act, dated 30.11.2021 wherein the income of the assessee company is stated to have been processed at an amount of Rs. 6,55,06,350/-. 68. As is discernible from the record, the assessee company had filed its return of income for AY 2020-21 on 24/12/2020, declaring its income

DR. REDDYS LABORATORIES LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

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

Bench: Shri Laxmi Prasad Sahu & Shri K.Narasimha Charyassessment Years: 2007-08 Dr.Reddy’S Laboratories Vs. Dcit,Circle-17(1) Limited Hyderabad 8-2-337, Road No.3 Banjara Hills Hyderabad-500 034

5. Since, there are adjustments prejudice to Company, the Company has filed objections before the Dispute Resolution Panel ("ORP"). Dispute Resolution Panel 6. During the proceedings before the ORP, the AO filed a letter dated 15.07.2011 (para 19, page 143 of paper book) before the ORP, requesting for allocation for corporate overhead expenses to all the 4 special units