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

3 ITA (TP) 104/Hyd/2022 Sanghi Industries Limited 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

INFOR (INDIA) PRIVATE LIMITED (FORMERLY KNOWN INFOR GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

92C(3) of the Act were satisfied. 7. On the facts and in the circumstances of the case and in law, the Ld. AO, Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Ld. TPO in classifying the Appellant as being engaged in providing a mix of high

INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRLCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

92C(3) of the Act were satisfied. 7. On the facts and in the circumstances of the case and in law, the Ld. AO, Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Ld. TPO in classifying the Appellant as being engaged in providing a mix of high

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

3 thereto. Therefore, he submitted that Section 153A differs from Section 147, which clearly indicates that the scheme of provision of Section 153A is different from that of Section 147. In :16: ITA Nos. 1717 to 1720/Hyd/2017 & this regard, he relied upon the following judicial precedents :  DCIT Vs. Eversmile Construction

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

68,70,340/-. The appellant-\ncompany has also filed Form-3CEB and reported various\ninternational transactions including provision of ITS and\nITES. The appellant-company is a captive service provider to\nit's AE on cost plus basis as per the agreement entered into\nby it with it's AEs. The appellant-company has carried-out\nTP analysis documents

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

92C(3) of the Act were satisfied. :- 6 -: ITA Nos..227 & 228/Hyd/2021 ADP Pvt. Ltd., Hyd. 11. On the facts and circumstances of the case and in contrary to law, the Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming the actions of the Ld. TPO in not allowing risk adjustment in accordance with

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

92C(3) of the Act were satisfied. :- 6 -: ITA Nos..227 & 228/Hyd/2021 ADP Pvt. Ltd., Hyd. 11. On the facts and circumstances of the case and in contrary to law, the Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming the actions of the Ld. TPO in not allowing risk adjustment in accordance with

CAMBRIDGE TECHNOLOGY ENTERPRISES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result assessee’s appeal stand partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

3. Erred in making an adjustment of Rs. 69,65,127/- towards arms length adjustment of receivables, without appreciating the fact that the assessee has not charged any interest on delayed payments received from both AE and Non-AE. ITA No.208/Hyd./2018 AY 2013-14 M/s Cambridge Technology Enterprises Ltd. 3.1. Erred in not appreciating the fact that the outstanding

MEDPLEXUS INDIA PVT. LTD., HYD,BANGALORE vs. ACIT, CIRLCE-16(2), HYD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2011-12 Medpluxes India Pvt. Ltd., Vs. Asst. Commissioner Of Income- Hyderabad. Tax, Circle – 16(2), Hyderabad. Pan – Aaecm7007N (Appellant) (Respondent) Assessee By : Shri Aliasger Rampurwala & Sri Abhiroop Bhargav Revenue By : Shri Y.V.S.T. Sai Date Of Hearing : 22-07-2019 Date Of Pronouncement : 05-09-2019 O R D E R

92C(3) of the Act and contending that the information or data used in the computation of the arm's length price is not reliable or correct. 4. That the learned AO/ DRP erred both in facts and in law in holding that the international transactions in the SWD segment and in the ITES segments of the Appellant does

DCIT, CIRCLE -2(1), HYDERABAD vs. TPSC(INDIA) PRIVATE LIMITED, HYDERABAD

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

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

68,929/-. Grievance of the assessee is that the learned P a g e 3 | 15 ITA-TP No. 225/Hyd/2022 Assessing Officer has taken the total revenue and total expenditure at Rs. 4,27,60, 39,978/- and Rs. 4,73,85,15,330/- respectively for the purpose of determining the Arm’s Length Price (ALP) which renders the revenue

ACIT, CIRCLE-17(1), HYDERABAD, HYDERABAD vs. DST WORLDWIDE SERVICES INDIA PVT. LTD., HYDERABAD, HYDERABAD

In the result, Revenue’s appeal is dismissed, while cross objections of the assessee are partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahasstt. Commissioner Of Vs M/S. Dst Worldwide Income Tax, Circle 17(1) Services India Pvt. Ltd Hyderabad Hyderabad Pan: Aaaci7097L (Appellant) (Respondent)

68,353”. 10. As regards the ground No.1, the assessee is aggrieved because the AO has not given the benefit of the proviso to sub- Page 5 of 7 ITA No 291 and CO No 24 of 2015 DST Worldwide Services India P Ltd Hyderabad. section (2) of section 92C of the Act. we find that

DY.COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD vs. LABZONE ELECTRONICS CITY PRIVATE LIMITED (FORMERLY KNOWN AS M/S ALEXANDRIA LABSPACE ELECTRONICS CITY PRIVATE LIMITED), HYDERABAD

Appeal is partly allowed for statistical purposes in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Raoassessment Year: 2013-14 The Deputy Commissioner Vs. M/S. Labzone Electronics Of Income Tax, City Private Limited Circle 16(1), (Formerly Known As M/S. Hyderabad. Alexandria Labspace Electronics City Private Limited), Hyderabad. Pan :Aajca1470G. (Appellant) (Respondent) Assessee By: Shri P.V.S.S. Prasad. Revenue By: Shri Yvst Sai. Date Of Hearing: 14.02.2022 Date Of Pronouncement: 23.02.2022 O R D E R Per S. S. Godara, J.M. This Revenue’S Appeal For A.Y. 2013-14 Arises From The Commissioner Of Income Tax (Appeals) – 4, Hyderabad’S Order Dated 17.07.2019 In Case No.10331/17-18/Dcit, Cir.1(1)/Cit(A)-4/Hyd/19-20, Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961 [In Short, ‘The Act’]. Heard Both The Parties. Case File Perused. 2. The Revenue’S Sole Substantive Grievance Raised In The Instant Appeal Challenges Correctness Of The Cit(A)’S Action Deleting Section 94A(4) Addition Of Rs.18,86,00,000/- Made In The Course Of Assessment Framed On 29.12.2016. The Cit(A)’S Lower Appellate Detailed Discussion To This Effect Reads As Follows :-

68 of the Act before the Assessing Officer afresh. 5. Learned authorized representative has drawn strong support from CIT(A)’s detailed discussion deleting the impugned addition made under section 94A of the Act. 6. We have given our thoughtful consideration to rival pleadings. The vexed question before us is of scope and ambit of section

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

92C(3) of the Income Tax Act, 1961 (hereinafter referred as “the Act”) in pursuance to the directions of the Dispute Resolution Panel – “DRP”, Bangalore-1’s for the assessment years 2011-12, 2012-13, 2013-14, 2012-13 and 2014-15 on the following grounds : Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

92C(3) of the Income Tax Act, 1961 (hereinafter referred as “the Act”) in pursuance to the directions of the Dispute Resolution Panel – “DRP”, Bangalore-1’s for the assessment years 2011-12, 2012-13, 2013-14, 2012-13 and 2014-15 on the following grounds : Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

92C(3) of the Income Tax Act, 1961 (hereinafter referred as “the Act”) in pursuance to the directions of the Dispute Resolution Panel – “DRP”, Bangalore-1’s for the assessment years 2011-12, 2012-13, 2013-14, 2012-13 and 2014-15 on the following grounds : Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

92C(3) of the Income Tax Act, 1961 (hereinafter referred as “the Act”) in pursuance to the directions of the Dispute Resolution Panel – “DRP”, Bangalore-1’s for the assessment years 2011-12, 2012-13, 2013-14, 2012-13 and 2014-15 on the following grounds : Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

92C(3) of the Income Tax Act, 1961 (hereinafter referred as “the Act”) in pursuance to the directions of the Dispute Resolution Panel – “DRP”, Bangalore-1’s for the assessment years 2011-12, 2012-13, 2013-14, 2012-13 and 2014-15 on the following grounds : Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement Limited, Kadapa Zuari Cement

AURONEXT PHARMA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

68,03,509/-. In this regard, the ld.AR submitted that the assessee had filed the rectification application before the Assessing Officer and the result is awaited. He had submitted ITA-TP No. 486/Hyd/2022 that the appropriate direction be issued for earlier disposal of the rectification application. 4.2. Per contra, the ld.DR has no objection for issuing the appropriate direction