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. 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

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

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

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

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

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

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

ORBIS REAL ESTATE FUND I,HYDERABAD (AUTH. REP.) vs. ADIT (INTERNATIONAL TAXATION)-2 - 2, HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

rectification petition under section 154 for rectifying the mistakes apparent from record on account of tax liability computation which was not agreed upon and the Assessee has proceeded to file a appeal against the 154 order before the Honorable commissioner of income tax (Appeals). In this regard, the process of filing the appeal before the Honorable ITAT has been delayed