PALRED TECHNOLOGIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

Appeal is partly allowed for statistical purposes

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahuassessment Year: 2008-09

transfer pricing documentation maintained by the assessee in accordance with the provisions of the Act read with the Income Tax Rules, 1962 ('Rules') and undertaking a fresh economic analysis during the course of assessment proceedings and accordingly making an adjustment of Rs 9,48,05,292 to the international transactions relating to provision of software services to its AE. Rejection

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

section 10A(7) and 80IA(10), when there is no export of software at all. The Ld.CIT(A) ought to have disallowed the entire deduction claimed by the assessee and upheld the order of the AO, since there was no software export, except body shopping. Thus, argued that the Department to be allowed and dismiss the cross appeals filed

CORTEVA AGRISCIENCE SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

In the result, the Ground No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Transfer Pricing Officer (“Ld. TPO”) and approved by the Ld. CIT(A) are functionally not comparable with the assessee, therefore, they are required to be excluded. In this regard, the Ld. AR had filed a written submission in support of his contention, which is to the following effect : “Exclusion of comparable companies chosen by TPO - Ground no. 9 In this

SIGNODE INDIA LIMITED,HYDERABAD vs. ACIT., CIRCLE 3(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Transfer Pricing Officer has made the adjustment on account of credit period provided by the assessee to the A.E. on realisation of sale proceeds. At the outset, we note that an identical issue has been considered by the co ordinate bench of the Tribunal, Mumbai Benches, in Goldstar Jewellery Ltd. (supra), vide Para– 8, held as under:– ITA No.1376/Hyd/2024

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LTD(ERSTWHILE EXCELLENCE DATA RESEARCH PRIVATE LIMITED),CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 Cognizant Technology Solutions Vs. Asst. Commissioner Of India Pvt. Ltd., (Erstwhile Income-Tax, Circle – 17(1), Excellence Data Research Pvt. Hyderabad. Ltd.), Chennai Pan – Aabce 4933C (Appellant) (Respondent)

section 115JB of the Income-tax Act, 1961 (in short ‘the Act’) and a total income of Rs. 14,19,335/- under the normal provisions of the Act. It had claimed deduction u/s 10A of the Act amounting to Rs. 6,95,70,554/- in the return of income. 2.1 The return was processed

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

Section 92F of the Income Tax Act is reproduced below- "(il) "arm's length price" means a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises, in uncontrolled conditions;” 5.0 It is clear from the above excerpt that the prices charged in transactions between parties which are Associated Enterprises

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH PRIVATE LIMITED),HYDERABAD vs. ACIT., CIRCLE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

Transfer Pricing Officer (TPO) for determining the Arms Length Price (ALP). The TPO, through an order under Section 92CA(3) of the Income Tax Act dated 31-10-2013, determined the ALP for these international transactions at Rs.7,24,90,047/-. Following this, a 7 final assessment order u/s 143(3) read with Section 92CA(3) and Section 144C

ACIT, CIRLCE-5 (1), , HYDERABAD vs. MARKET TOOLS RESEARCH PRIVATE LIMITED , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

Transfer Pricing Officer (TPO) for determining the Arms Length Price (ALP). The TPO, through an order under Section 92CA(3) of the Income Tax Act dated 31-10-2013, determined the ALP for these international transactions at Rs.7,24,90,047/-. Following this, a 7 final assessment order u/s 143(3) read with Section 92CA(3) and Section 144C