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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

ITA 866/HYD/2015[2007-08]Status: DisposedITAT Hyderabad17 Dec 2019AY 2007-08

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

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

ITA 864/HYD/2015[2005-06]Status: DisposedITAT Hyderabad17 Dec 2019AY 2005-06

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 869/HYD/2015[2010-11]Status: DisposedITAT Hyderabad17 Dec 2019AY 2010-11

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 834/HYD/2015[2008-09]Status: DisposedITAT Hyderabad17 Dec 2019AY 2008-09

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 868/HYD/2015[2009-10]Status: DisposedITAT Hyderabad17 Dec 2019AY 2009-10

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 832/HYD/2015[2006-07]Status: DisposedITAT Hyderabad17 Dec 2019AY 2006-07

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 835/HYD/2015[2009-10]Status: DisposedITAT Hyderabad17 Dec 2019AY 2009-10

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 836/HYD/2015[2010-11]Status: DisposedITAT Hyderabad17 Dec 2019AY 2010-11

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 831/HYD/2015[2005-06]Status: DisposedITAT Hyderabad17 Dec 2019AY 2005-06

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 833/HYD/2015[2007-08]Status: DisposedITAT Hyderabad17 Dec 2019AY 2007-08

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 867/HYD/2015[2008-09]Status: DisposedITAT Hyderabad17 Dec 2019AY 2008-09

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

ITA 865/HYD/2015[2006-07]Status: DisposedITAT Hyderabad17 Dec 2019AY 2006-07

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

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

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

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

ITA 1632/HYD/2017[2010-11]Status: DisposedITAT Hyderabad05 Aug 2024AY 2010-11

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Rajan Vora, C.AFor Respondent: : Shri Kumar Pranav, CIT-DR

Section 10ASection 115Section 115JSection 251(1)(a)Section 37(1)Section 41(1)

transferred to unclaimed liabilities account. The assessee, during the appellate proceedings furnished the details of these unclaimed liabilities as additional evidence and the same was sent to Assessing officer for factual report. However, till date no report is received. 7.1 On perusal of the details furnished it is seen that in case of many entries there is not even

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

Appeal is partly allowed for statistical purposes

ITA 581/HYD/2020[2008-09]Status: DisposedITAT Hyderabad08 Sept 2021AY 2008-09

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

For Appellant: Sri Ravi BharadwajFor Respondent: Sri Rohit Mujumdar, DR

Section 10ASection 133(6)Section 143(3)Section 234BSection 271

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

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 606/HYD/2016[2012-13]Status: DisposedITAT Hyderabad31 Jul 2023AY 2012-13

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A

Section 143(3)Section 153ASection 80I

transfer does not come.” 7 M/s. HES Infra Pvt. Ltd. 4. Aggrieved by the order of Assessing Officer, the assessee filed an appeal before the ld.CIT(A). The ld.CIT(A) after considering the submissions of the assessee, allowed the appeal of the assessee. Aggrieved by the order of ld.CIT(A), the Revenue is now in appeal before

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 604/HYD/2016[2010-11]Status: DisposedITAT Hyderabad31 Jul 2023AY 2010-11

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A

Section 143(3)Section 153ASection 80I

transfer does not come.” 7 M/s. HES Infra Pvt. Ltd. 4. Aggrieved by the order of Assessing Officer, the assessee filed an appeal before the ld.CIT(A). The ld.CIT(A) after considering the submissions of the assessee, allowed the appeal of the assessee. Aggrieved by the order of ld.CIT(A), the Revenue is now in appeal before

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 603/HYD/2016[2009-10]Status: DisposedITAT Hyderabad31 Jul 2023AY 2009-10

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A

Section 143(3)Section 153ASection 80I

transfer does not come.” 7 M/s. HES Infra Pvt. Ltd. 4. Aggrieved by the order of Assessing Officer, the assessee filed an appeal before the ld.CIT(A). The ld.CIT(A) after considering the submissions of the assessee, allowed the appeal of the assessee. Aggrieved by the order of ld.CIT(A), the Revenue is now in appeal before

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 605/HYD/2016[2011-12]Status: DisposedITAT Hyderabad31 Jul 2023AY 2011-12

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A

Section 143(3)Section 153ASection 80I

transfer does not come.” 7 M/s. HES Infra Pvt. Ltd. 4. Aggrieved by the order of Assessing Officer, the assessee filed an appeal before the ld.CIT(A). The ld.CIT(A) after considering the submissions of the assessee, allowed the appeal of the assessee. Aggrieved by the order of ld.CIT(A), the Revenue is now in appeal before

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

In the result, the Ground No

ITA 253/HYD/2017[2011-12]Status: DisposedITAT Hyderabad23 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Sandeep Bansal, CA and Shri Rohit Mittal, CAFor Respondent: : Shri Shakeer Ahamed, DR

Section 143(3)Section 144C(4)Section 92C

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

ITA 1376/HYD/2024[2021-22]Status: DisposedITAT Hyderabad25 Jul 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri H. Srinivasulu, C.AFor Respondent: Dr. Sachin Kumar, SR-DR

Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

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