OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (I) PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Transfer Pricing Grounds (i.e Ground 1 to 11) 13. Non-grant of MAT credit available to the Company. Without prejudice to the above grounds, that on facts and circumstances of the case, the Ld. AO has grossly erred in law as well as in facts, in non-grant of MAT Credit available, amounting

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

Transfer Pricing Officer (“TPO”) on 25/10/2019 for determining the Arm’s Length Price (“ALP”) after obtaining the necessary approvals from the Ld. Pr. CIT-3, Hyderabad, dated 18/10/2019. Accordingly, notice U/s. 92CA(2) of the Act was issued on 26/11/2019 and subsequent notice / questionnaire was also issued on 29/12/2020. In response, the assessee filed its submissions on 23/10/2020 and 12/12/2020

UBER INDIA SYSTEMS PRIVATE LIMITED (AS SUCCESSOR TO UBER INDIA RESEARCH AND DEVELOPMENT PRIVATE LIMITED),HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

transfer pricing order without application of mind inasmuch as the learned TPO have mixed the Appellant's functions and the contentions with another taxpayer. Levy of interest under Section 234D of the Act 18. On the facts and in circumstances of the case and in law, the learned NFAC / AO erred in levying interest under Section 234D

MICROSOFT GLOBAL SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

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

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

transfer pricing adjustment of Rs. 95,16,40,000/-. On receipt of the order u/s 92CA(3) from the TPO, draft Assessment Order was completed on 25.12.2019 and the sum proposed by the TPO was added to the income of the assessee. 3. Aggrieved with such draft assessment order, assessee company filed objections with the Dispute Resolution Panel

TMEIC INDUSTRIAL SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2(1), HYDERABAD

In the result, both the Writ Petitions are allowed by setting aside the impugned assessment orders dated

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.422/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2018-19) Tmeic Industrial Systems Vs. Dy. Cit India Private Limited Circle 2 ( 1 ) Hyderabad Hyderabad Pan:Aadct5493J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Cas, Kranthi Palivela & Mrudulatha Devdas राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 17/12/2024 घोषणा की तारीख/Pronouncement: 24/02/2025 आदेश/Order

transfer pricing adjustment in the nature of interest on receivables amounting to INR 3,41,506/- b) Not appreciating that the instant transaction is not covered in the definition of international transaction as defined u/s 92B of the Act in the facts and circumstances of the case: c) Delinking the inter-company receivables arising from the main international transactions

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

Bench: Us:

transfer pricing study report for benchmarking the said international transaction of provision of SDS services: •Inteq Software Pvt Ltd. •Yudiz Solutions Pvt. Ltd •R Systems International Ltd •Sasken Technologies Ltd. •Info Bears Technologies Ltd. 1.5 The learned AO erred in law and in facts in rejecting the following additional comparable companies proposed by the Appellant for 3 HighRadius Technologies Private

INTERWRAP CORP PRIVATE LIMITED (SUCCESSOR OF OWENS CORNING INDUSTRIES (INDIA) PRIVATE LIMITED),MUMBAI 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 VIJAY PAL RAO, HON'BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

transfer pricing adjustment of Rs. 47,92,29,000/- towards purchases. The 8 Interwrap Corp Private Ltd Hon’ble DRP also directed deletion of the addition of Rs. 5,99,097/- relating to delayed deposit of PF/ESIC, as the same had already been deleted by the CIT(A) in earlier proceedings and could not be added again. Penalty

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)

transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 5,08,183. 8 ADP Private Limited b) Not appreciating that the receivables are consequential/closely linked to the principal transaction of provision of services and hence have been aggregated for determination of Arm's Length Price ('ALP') under Transactional Net Margin Method ('TNMM'). c) Not appreciating

LIMAGRAIN INDIA PRIVATE LIMITED,SECUNDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

penalty i.e. the transfer pricing adjustment, is itself under reconsideration, we are of the view that the penalty proceedings under

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

Bench: Us:

Pricing Officer ('Ld. TPO')/Ld. AO in proposing an adjustment of INR 19,43,26,338 to the specified domestic transactions ('SDTs') pertaining to inter-unit transfer of milk. 3. On the facts and circumstances of the case, and in law, the Ld. AO / Ld. TPO / Ld. Panel erred in rejecting the economic analysis carried out in TP documentation which

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

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

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

transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 2,80,004. 12. On the facts and circumstances of the case and in contrary to law, the addition made by the Ld. TPO with respect to interest on outstanding receivables is untenable and be deleted since the addition has been made by computing interest

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

transfer pricing documentation. 6. On the facts and in the circumstances of the case and in law, the Ld. AO/Ld. TPO/Hon'ble DRP erred in rejecting certain filters applied by the Appellant. 7. On the facts and in the circumstances of the case and in law, the Ld. AO/Ld. TPO/Hon'ble DRP erred in applying certain additional filters which

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

Transfer Pricing Officer (TPO) while completing the assessment under section 92CA of the Income tax Act, 1961 made an addition of Rs. 10,62,036/- by way of notional interest on outstanding export receivables realized beyond 60 days. 4. The learned Assessing Officer passed a draft assessment order U/s 144C read with section 143(3) of the Income

FAIRFIELD DEVELOPMENT LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX ,(INTERNATIONAL TAXATION), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 M/S. Fairfield Developments Vs. Dy. Commissioner Of Income Limited, Tax, Hyderabad. International Taxation – 1 Pan : Aabcf3158N Hyderabad. (Appellant) (Respondent) Ita 488/Hyd/2019 Assessment Year 2014-15 Dy. Commissioner Of Income Vs. M/S. Fairfield Developments Tax, Limited, International Taxation – 1, Hyderabad. Hyderabad. Pan : Aabcf3158N (Appellant) (Respondent) Assessee By: Shri Akshay Surana & Siddharth Surana, C.A Revenue By: Shri K.P.R.R. Murthy Date Of Hearing: 27.03.2023 Date Of Pronouncement: 25.04.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 10, Hyderabad Dated 16.01.2019 For The Assessment Year 2014-15. 2 M/S. Fairfield Developments Limited

Transfer Pricing Officer (TPO) and the total TP adjustment made on international transactions was of Rs.13,98,41,656/-. The AO has correctly taxed the excess interest income of Rs.13,98,41,656/- @ 40% relying on Article 11(7) of the India-Cyprus DTAA. The view taken in other assessment years is not relevant as the principle of res judicata

DY. COMMISSIONER OF INCOME TAX ,(INTERNATIONAL TAXATION)-1, HYDERABAD vs. FAIR FIELD DEVELOPMENT LIMITED , CYPRUS

In the result, the appeal of Revenue in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 M/S. Fairfield Developments Vs. Dy. Commissioner Of Income Limited, Tax, Hyderabad. International Taxation – 1 Pan : Aabcf3158N Hyderabad. (Appellant) (Respondent) Ita 488/Hyd/2019 Assessment Year 2014-15 Dy. Commissioner Of Income Vs. M/S. Fairfield Developments Tax, Limited, International Taxation – 1, Hyderabad. Hyderabad. Pan : Aabcf3158N (Appellant) (Respondent) Assessee By: Shri Akshay Surana & Siddharth Surana, C.A Revenue By: Shri K.P.R.R. Murthy Date Of Hearing: 27.03.2023 Date Of Pronouncement: 25.04.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 10, Hyderabad Dated 16.01.2019 For The Assessment Year 2014-15. 2 M/S. Fairfield Developments Limited

Transfer Pricing Officer (TPO) and the total TP adjustment made on international transactions was of Rs.13,98,41,656/-. The AO has correctly taxed the excess interest income of Rs.13,98,41,656/- @ 40% relying on Article 11(7) of the India-Cyprus DTAA. The view taken in other assessment years is not relevant as the principle of res judicata

DSM SHARED SERVICES INDIA PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 8(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1358/Hyd/2024 Assessment Year 2021-2022 Dsm Shared Services India Private Limited, The Dcit, Circle-8(1), Hyderabad – 500 081. Hyderabad – 500 081. Vs. Telangana. Telangana. Pan Aadcd8407C (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09.12.2025 घोषणा की तारीख/Pronouncement: 12.12.2025 आदेश/Order

transfer pricing adjustment of INR 8,60,80,441 towards provision of ITes. 3 ITA.No.1358/Hyd./2024 4. On the facts and circumstances of the case and in law, the Hon'ble DRP/Ld. AO/TPO have further erred in : a. rejecting the economic analysis carried out in TP documentation which was maintained in good faith and with due diligence despite satisfying

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

transfer pricing adjustment can be made on hypothetical and notional basis without there being any material on record justifying the fact that there had been under charging of such interest on real income. 2.9. Erred in directing TPO to adopt the six month average LIBOR plus 250 basis points. 3. Erred in upholding the upward adjustment of Arm’s Length

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

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)

penalty proceedings under Section 270A and 271AA, without considering the fact that the aforesaid transfer pricing adjustment is on account