CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

In the result, all the appeals of the assessee are allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

pricing pressures, which is common among developers in a highly competitive sector. 35 SABIR, SEW & PRASAD JV 16.4. We have also noted the off-balance sheet items of liabilities i.e. Contingent liabilities and observe that there's a significant increase in contingent liabilities, especially in guarantees for joint ventures and disputed tax and royalty demands, which indicate growing exposure

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

RAMESH CHANDRA MAJITHIA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

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

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra

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

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra

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

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra

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

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra

HIMASAGAR KRISHNA MUTHAPPAGARI,TIRUPATI vs. ITO., WARD-2(3), TIRUPATI

Bench: Us.

120; [(iii) an order under section 92CA by the Transfer Pricing Officer;] (b) "record" shall include and shall be deemed always to have included all records relating to any proceeding under this Act available at the time of examination by the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner; (c) where any order referred to in this

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

section 153 of the Act which is the outer time limit for passing the final assessment order and hence, the assessment proceedings are time barred and liable to be quashed. TRANSFER PRICING GROUNDS 3. erred in making a transfer pricing ("TP") adjustment of INR 3,41,54,276 in relation to notional interest on overdue inter-company receivables and payment

VENKATA KRISHNA TATINENI,SECUNDERBAD vs. ASST COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

120; ITA No.604/Hyd/2023 9 82[(iii) an order under section 92CA by the Transfer Pricing Officer;] (b) "record" shall include and shall be deemed always to have included all records relating to any proceeding under this Act available at the time of examination by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner; (c) where any order

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

B’ Bench, Hyderabad श्री विजय पाल राि, उपाध् यक्ष एिं श्री मिुसूदन सािडिया, लेखा सदस् य के समक्ष । BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA No.1376/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2021-22) M/s. Signode India Limited, Asst. Commissioner of Income Tax, Vs. Hyderabad. Circle 3(1), Hyderabad. PAN:AAHCS8120M (Appellant

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

IVY COMPTECH PRIVATE LIMITED,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuay : 2013-14 Ivy Comptech Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1) Hyderabad. Pan – Aaaci 8884K (Appellant) (Respondent) Assessee By: Shri Prashant Meharchandani Revenue By: Shri R. Dipak Date Of Hearing: 27/04/2021 Date Of Pronouncement: 20/07/2021

Transfer Pricing study and the mean of working capital adjustment margins of the comparable companies was arrived at 13.18% for IT segment and 13.95% for ITES segment. The price earned by the Appellant was concluded to be at arm's length as the margins earned by the Appellant of 17.55% from IT segment and 25.61% from ITES segment was higher

OSI SYSTEMS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri P. Madhavi Devi & D.S. Sunder Singh(Through Video Conference) Assessment Year: 2013-14 Osi Systems Pvt. Ltd., Vs. Dy. Commissioner Of Income- Hyderabad. Tax, Circle – 16(2), Hyderabad. Pan – Aaaco 4438M

B 59016276 40978543 16299432 10800148 127094399 Profit OP/OC% D= 22.00 23.03 31.02 18.70 C/B% E= OP/OR% C/A% 5.63 15.75 Compara-ble margin F (0.84) 15.69 17.85 OP/OC% OP/OR% G 2.24 4.1 The assessee further submitted that the excess profit earned by the assessee was Rs. 8,77,55,919/-, which takes care of of the adjustments that are required

DAICEL CHIRAL TECHNOLOGIES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2017-18 M/S. Daicel Chiral Vs. 1. Deputy Technologies India Private Commissioner Of Limited, Income Tax, Circle Medchal, 8(1), Hyderabad. Hyderabad. 2. National Faceless Pan : Aaccd8423B. Assessment Centre, Delhi. (Appellant) (Respondent) Assessee By: Shri N. Pradeep Revenue By: Shri T. Vijaya Bhaskar Reddy Date Of Hearing: 01.02.2023 Date Of Pronouncement: 03.02.2023 O R D E R Per Laliet Kumar, J.M.

Transfer Pricing Officer-3, Hyderabad. Thereafter, the TPO after considering the submissions of the assessee passed an order under section 92CA(3) dated 29/01/2021 with an adjustment amounting to Rs.2,71,91,368/- to the total income of the assessee. Accordingly, a draft assessment order was served upon the assessee on 30.03.2021. 2.3 Aggrieved by the action of the TPO/AO