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

In the result, appeal of the Assessee for the\n

68,62,731 towards interest on outstanding receivables.\n2. On the facts and in the circumstances of the case and in law, the\nLd. TPO erred and the Hon'ble DRP further erred in\nupholding/confirming the action of the Ld. TPO, in rejecting the\ntransfer pricing analysis/study prepared by the Appellant and\nconducting fresh benchmarking, without appreciating that none

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

Bench: Us:

144C(3) r.w.s 144B of the Act, dated 15.07.2022 to an amount of Rs. 2,08,033/-. The Ld. AR assailed the disallowance of the aforesaid interest expenditure for two reasons, viz (i). that as the amount advanced by the assessee company to its Managing Director, i.e., an employee, at a discounted interest rate, was in the nature

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

8. That in the facts and circumstances of the case, the Ld. AO is not justified in determining the tax payable including interest Rs. 60,06,68,444/- 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

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

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

SSNC FINTECH SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

8.\nFurther, the Id. AO/TPO/DRP erred in law\nand in facts of the case modifying the filter of extra-\nordinary events and rejecting the filter of inadequate\nbusiness segment information.\n2:9.\nThe Id. AO/TPO/DRP erred in selecting the\ncompanies only if the data pertaining to FY 2019-20 is\navailable in the public databases.\n2:10. The Id. AO/TPO/DRP

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

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

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

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

8 income in India from immovable property of Rs. 1.22 lakhs and interest on deposits on which TDS was deducted, that he duly declared this income in the return of income filed on 25/10/2021 in response to notice issued under section 148 dated 24/06/2021 admitting total income of Rs. 3,68,920/-. Assessee further submitted that the cash deposits

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/- in its return, which was processed under section 143(1) of the Act by the CPC, resulting in a disallowance of ₹5,13,01,761/- towards gratuity expenses under section 43B of the Act. This adjustment increased the assessee’s income to ₹ 63,40,69,950/-. Subsequently, the case of the assessee was selected for scrutiny

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

AUROBINDO PHARMA LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), HYDERABAD

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

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

144C(5) of the Act. ITA-TP No. 1860/Hyd/2019 2. The grounds raised by the assessee read as under : “A. General 1. The subject order of Ld. Dispute Resolution Panel (DRP) / Ld Assessing Officer (AO) is erroneous in law and on the facts of the case in respect of the following grounds: B. Transfer Pricing (TP) Grounds (i) Corporate Guarantee

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

8. The Learned DRP/AO/TPO ought to have appreciated that the Assessee has not received any amount in the form of interest on delayed receipt of receivables from either Associated enterprises or third-parties including indigenous parties and that not charging any interest from AEs on the trade receivables is consistent with the Arm's length principle. Page

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

DCIT., (INTERNATIONAL TAXATION)-1, HYDERABAD vs. SYAMA REDDY MALI REDDY, HYDERABAD

68,370/-\nby an amount of Rs.7,58,13,772/-. Apart from that, the A.O.\ndeclined the assessee's claim for deduction under Section 54 of the\nAct on two grounds, viz. (i) the assessee had not purchased the new\nresidential house within two years from the date of transfer of the\noriginal asset; and (ii) the assessee owned