APACHE FOOTWEAR INDIA PRIVATE LIMITED,MAMBATTU VILLAGE vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CIRCLE-1(1), TIRUPATI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

Transfer Pricing Officer)-1, Hyderabad and an order u/s. 92CA(3) of the Income- tax Act, 1961 was passed by him on 22.01.2021 determining the upward adjustment of Rs.15,45,798/- u/s. 92CA of the Act, mentioning as “assessment order”. 3.3 Subsequently, the TPO passed rectification order u/s. 92CA(3) r.w.s. 154

M/S NAGARJUNA FERTILIZERS AND CHEMICALS LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

In the result, both the appeals of the assessee are partly allowed

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

rectification Nagarjuna Fertilizers and Chemicals Ltd., Hyd. order u/s 92CA(5) r.w.s. 154 dated 24/02/2016, revised the adjustment u/s 92CA(3) to Rs. 1,20,49,257/-. 4. Aggrieved by the order of TPO, the assessee raised objections before the DRP and DRP directed the TPO to apply the interest rate @ 12.13% as against the SBI PLR @ 14.75% applied

NAGARJUNA FERTILIZERS AND CHEMICALS LIMITED, HYDERABAD,HYDERABAD vs. ACIT, CIRLCE-16(1), HYDERABAD, HYDERABAD

In the result, both the appeals of the assessee are partly allowed

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

rectification Nagarjuna Fertilizers and Chemicals Ltd., Hyd. order u/s 92CA(5) r.w.s. 154 dated 24/02/2016, revised the adjustment u/s 92CA(3) to Rs. 1,20,49,257/-. 4. Aggrieved by the order of TPO, the assessee raised objections before the DRP and DRP directed the TPO to apply the interest rate @ 12.13% as against the SBI PLR @ 14.75% applied

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)

u/s 144C(5) of the Act, is bad in law and void ab initio so far as it is prejudicial to the Appellant. Transfer Pricing Adjustment 2. That on the facts and circumstances of the case and in law, the Lid. TPO/Ld, AO erred in making transfer pricing adjustment of Rs. 47,92,29,000 on account of adjustment towards

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

Bench: Us:

transfer pricing issues on comparability cannot constitute a precedent to be blindly followed ad infinitum. Whether a particular company is a comparable or not is an exercise which has to be carried out every year in the case of an Assessee considering the facts of that specific year and not blindly following the precedent which has been laid down

ZUARI CEMENT LIMITED,KADAPA vs. DCIT, CIRCLE -1, KURNOOL

In the result, both the appeals preferred by the assessee are treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent Zuari Cement 249/Hyd/2021 2016-17 Dcit, Limited, Circle-1, Yerraguntla, Kurnool Kadapa District 132/Hyd/2022 2017-18 [Pan: Aaacz1270E]

u/s. 92CA. Assessee filed various objections before the DRP but more or less concurred with TPO vide its order dt.25-11-2013. Assessee is aggrieved. 10. Assessee's objections are multi-fold. Ground No.1 & 2 are general in nature. Ground No.3 & 4, is the method adopted by the TPO and Ground No.5 to 12 are on various disallowances made

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

In the result, both the appeals preferred by the assessee are treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent Zuari Cement 249/Hyd/2021 2016-17 Dcit, Limited, Circle-1, Yerraguntla, Kurnool Kadapa District 132/Hyd/2022 2017-18 [Pan: Aaacz1270E]

u/s. 92CA. Assessee filed various objections before the DRP but more or less concurred with TPO vide its order dt.25-11-2013. Assessee is aggrieved. 10. Assessee's objections are multi-fold. Ground No.1 & 2 are general in nature. Ground No.3 & 4, is the method adopted by the TPO and Ground No.5 to 12 are on various disallowances made

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

transfer pricing adjustment. He further submitted that, the assessee had entered into a Bilateral Advance Pricing Agreement (“BAPA”) u/s.92CC of the Act, which cover the assessment year under consideration and in the light of the BAPA, the assessee seeks the withdraw ground no.1. Accordingly, the Ld. AR invited our attention to the withdrawal request of ground no.1 placed at page

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

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

rectification petition filed/pending before the Assessing Officer. Rejected accordingly. 13. The assessee’s 22nd substantive ground seeks to allow education cess paid as a deduction involving an amount of Rs.52,84,078/- in issue. The Revenue on the other hand quotes Section 40(a)(ii) of the Act that a “cess” very much forms part of the clinching statutory expression

MYLAN LABORATORIES LTD,(FORMERLY MATRIX LABORATORIES LIMITED), HYD HYD,HYDERABAD vs. DCIT, CIRCLE-16(2), HYD, HYDERABAD

In the result, appeal of Revenue is partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

Transfer Pricing Order. The AO vide his draft order determined the total income at Rs. 2,35,76,34,030/- under normal computation and at Rs.3,00,07,52,895/- u/s. 115JB. 2.2. Assessee vide letter dated 16-04-2014 accepted the Draft Assessment Order (without prejudice to its right of appeal under the Act) in terms of sub-section

DCIT, CIRCLE-16(2), HYD, HYDERABAD vs. MYLAN LABORATORIES LTD., HYD, HYDERABAD

In the result, appeal of Revenue is partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

Transfer Pricing Order. The AO vide his draft order determined the total income at Rs. 2,35,76,34,030/- under normal computation and at Rs.3,00,07,52,895/- u/s. 115JB. 2.2. Assessee vide letter dated 16-04-2014 accepted the Draft Assessment Order (without prejudice to its right of appeal under the Act) in terms of sub-section

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED (FORMERLY KNOWN AS IGATE GLOBAL SOLUTIONS LIMITED), M/S IGATE INFORMATION SERVICES PRIVATE LIMITED MERGED WITH IGATE GLOBAL SOLUTIONS LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(1), HYDERABAD

Appeal is partly allowed for statistical purposes in above terms

Bench: Shri S.S. Godara & Shri L.P. Sahu

154 of the Income Tax Act, 1961 [ in short ‘the Act’ ]. Heard both the parties. Case file perused. 2. The assessee has pleaded the following substantive grounds in the instant appeal. 1. On the facts and in the circumstances of the case, the order of the Commissioner of Income Tax (Appeals)-l, Guntur, is erroneous, illegal and unsustainable

DR REDDYS LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-8(1), HYDERABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G., Hon’Bleआ.अपी.सं /Ita No.409/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2011-12) Dr. Reddy’S Laboratories Deputy Commissioner Limited Vs. Of Income Tax Hyderabad Circle-8(1) [Pan: Aaacd7999Q] Hyderabad (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri S.P.Chidambaram, Ar राज" व "ारा/Revenue By: Shri B.Bala Krishna, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Date Of 07/04/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 09.06.2023 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal:

rectification order u/s 154 of the Act was passed on 22.03.2016, assessing income at Rs.478,02,51,739/- under normal provisions of the Act and book profit at Rs.1036,54,01,910/- under MAT provisions. 4. The assessment has been subsequently reopened u/s 147 of the Act for the reasons recorded, as per which, the income chargeable

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE-1(4), HYDERABAD vs. MEDHA SERVO DRIVES PRIVATE LIMITED, HYDERABAD

In the result, the CO filed by the assessee is allowed

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

U/s. 14A of the Act has rightly been allowed by the Ld. CIT(A). We find from the order of the Ld. CIT(A) that there is no exempt income earned by the assessee during the impugned assessment year and he has relied on certain judgments while deciding the issue in favour of the assessee. The Hon’ble Delhi High

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE-1(4), HYDERABAD vs. MEDHA SERVO DRIVES PRIVATE LIMITED, HYDERABAD

In the result, the CO filed by the assessee is allowed

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

U/s. 14A of the Act has rightly been allowed by the Ld. CIT(A). We find from the order of the Ld. CIT(A) that there is no exempt income earned by the assessee during the impugned assessment year and he has relied on certain judgments while deciding the issue in favour of the assessee. The Hon’ble Delhi High

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED (PREVIOUSLY KNOWN AS APPLABS TECHNOLOGIES PRIVATE LIMITED),HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee for the A

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

rectification petition filed by the Appellant in relation to mistake apparent from record in considering the professional fees incurred pursuant to acquisition expenses as non-operating in nature. Corporate Guarantee 13. The learned TPO and the learned AO have erred, in law, facts and circumstances of the case in making a TP addition to the transactions relating to provision

APPLABS TECHNOLOGIES PVT LTD (NOW MERGED WITH COMPUTER SCIENCE CORPORATION PVT LTD ),,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1, HYDERABAD

In the result, the appeal of the assessee for the A

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

rectification petition filed by the Appellant in relation to mistake apparent from record in considering the professional fees incurred pursuant to acquisition expenses as non-operating in nature. Corporate Guarantee 13. The learned TPO and the learned AO have erred, in law, facts and circumstances of the case in making a TP addition to the transactions relating to provision

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD vs. APPLABS TECHNOLOGIES PVT. LTD. (NOW MERGED WITH M/S COMPUTER SCIENCE INDIA PVT. LTD.), HYDERABAD

In the result, the appeal of the assessee for the A

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

rectification petition filed by the Appellant in relation to mistake apparent from record in considering the professional fees incurred pursuant to acquisition expenses as non-operating in nature. Corporate Guarantee 13. The learned TPO and the learned AO have erred, in law, facts and circumstances of the case in making a TP addition to the transactions relating to provision