SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

H HC)], it was held that estimation at 8% on gross receipts is valid when books are not reliable. Likewise, in CIT v. Banwarilal Banshidhar [(1998) 229 ITR 229 (AII HC)], it was held that once estimation is made. it is a valid method of computation where books are unreliable. Therefore, the estimation made by the AO is justified

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

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)

13) read with section 144B of the Act, dated 06 December 2024 is illegal and void in as much as it is barred by limitation as the order is passed beyond the time limit prescribed under section 153 of the Act and therefore the order, is liable to be set aside. Grounds relating to corporate tax: 2. Ground 2: Erroneous

CALLIDUSCLOUD (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

2. Legal Ground – Timelines under Section 153 of the Act 2.1. On the facts and in the circumstances of the case and in law, the Final Assessment Order dated 23.10.2024 passed by the Assessment Unit under Section 143(3) r.w.s. Section 144C(13) r.w.s. Section 144B of the Act is barred by limitation and therefore is void-ab-initio

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

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (I) PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

2) Rejecting the use of multiple year data and using data for the FY 2012-13 only; Use of additional filters 3) Inter-alia use of the following additional/modified filters in undertaking the comparative analysis and rejecting comparable companies having: (a) Different financial year-end; and (b) Export sales less than 75% of the sales Selection of companies

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

2) Rejecting the use of multiple year data and using data for the FY 2012-13 only; Use of additional filters 3) Inter-alia use of the following additional/modified filters in undertaking the comparative analysis and rejecting comparable companies having: (a) Different financial year-end; and (b) Export sales less than 75% of the sales Selection of companies

MYLAN LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER INCOME TAX , CIRCLE-5 (1) , HYDERABAD

In the result, the ground no

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

H), it was held that a mere audit objection cannot lead to an inference that the order of the Assessing Officer was erroneous or prejudicial to the interest of the Revenue, where there was no indication that the Commissioner notes was himself satisfied about it prior to issue of notice, so that his order in pursuance of a notice based

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

H. Srinivasulu, C.A. रधजस् व द्वधरध/Revenue by: Dr. Sachin Kumar, SR-DR सुिवधई की तधरीख/Date of hearing: 17/07/2025 घोर्णध की तधरीख/Pronouncement: 25/07/2025 आदेश/ORDER PER MADHUSUDAN SAWDIA, A.M. : This appeal is filed by M/s. Signode India Limited (“the assessee”), feeling aggrieved by the order passed by the Learned Assessing Officer (“Ld. AO”) u/s.143(3) r.w.s. 144C(13

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

H. Srinivasulu, Advocate For Revenue : Dr. Narendra Kumar Naik, CIT-DR Date of Hearing : 25.08.2025 Date of Pronouncement : 14.11.2025 ORDER PER MANJUNATHA G. : These appeals have been filed by the assessee- company against (i) the Final Assessment Order dated 26.04.2021 passed by the A.O. under Section 143(3) r.w.s. 2 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited 144C(13

SIGNODE INDIA LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

H. Srinivasulu, Advocate For Revenue : Dr. Narendra Kumar Naik, CIT-DR Date of Hearing : 25.08.2025 Date of Pronouncement : 14.11.2025 ORDER PER MANJUNATHA G. : These appeals have been filed by the assessee- company against (i) the Final Assessment Order dated 26.04.2021 passed by the A.O. under Section 143(3) r.w.s. 2 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited 144C(13

PATHFINDER PUBLISHING PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE -16(2), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

transfer at general body meeting of the company; (iii) reserve and surplus, by whatever name called, even if the resulting figure is negative, other than those set apart towards depreciation; (iv) any amount representing provision for taxation, other than amount of tax paid as deduction or collection at source or as advance tax payment as reduced by the amount

PAREXEL INTERNATIONAL (INDIA) PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (for short “the ITA-TP No. 488/Hyd/2022 Act”), consequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru (“DRP”), assessee filed this appeal. 2. Brief facts of the case as per record are that the assessee is a subsidiary of Parexel International Holdings B.V., Netherlands which

TEK SYSTEMS GLOBAL SERVICES PRIVATE LIMITED,HYDERBAD vs. DCIT, CIRCLE-2(1), HYDERBAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.487/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2018-19) Tek Systems Global Vs. Dy. C. I. T. Services (P) Ltd, Circle 2(1) Hyderabad Hyderabad Pan:Aabcf1518Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms. K. Amulya, Ca रधजस् व द्वधरध/Revenue By:: Shri Jeevan Lal Lavidiya, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 29/05/2024 घोर्णध की तधरीख/Pronouncement: 05/07/2024 आदेश/Order

transfer agreement ("BTA") dated 28.03.2017. 2. In the assessment proceeding concluded in the case of the Appellant for the said preceding AY, the lower authorities disallowed the depreciation claimed on the said Goodwill as a consequence of disregarding the said Goodwill. 3. In light of the above, the disallowed the depreciation claimed in the Impugned AY, on the opening

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NCL GREEN HABITATS PRIVATE LIMITED, HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

h) by way of transaction not regarded as transfer under clause (vicb) or clause (vid) or clause (vii) of section 47.] (f) "stamp duty value" means the value adopted or assessed or assessable by any authority of the Central Government or a State Government for the purpose of payment of stamp duty in respect of an immovable property;] 52[(viia

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

2), Hyderabad in ITA No:485/Hyd/2022 dated 27.04.2023 wherein we have also granted the credit period of 60 days, which is also in the same of line of business. No special treatment can be given to the assessee. Furthermore, once the assessee failed to justify and substantiate the credit period of 90 days before the lower authorities, it is preposterous

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD, HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

2), Hyderabad in ITA No:485/Hyd/2022 dated 27.04.2023 wherein we have also granted the credit period of 60 days, which is also in the same of line of business. No special treatment can be given to the assessee. Furthermore, once the assessee failed to justify and substantiate the credit period of 90 days before the lower authorities, it is preposterous

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

2), Hyderabad in ITA No:485/Hyd/2022 dated 27.04.2023 wherein we have also granted the credit period of 60 days, which is also in the same of line of business. No special treatment can be given to the assessee. Furthermore, once the assessee failed to justify and substantiate the credit period of 90 days before the lower authorities, it is preposterous

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

2), Hyderabad in ITA No:485/Hyd/2022 dated 27.04.2023 wherein we have also granted the credit period of 60 days, which is also in the same of line of business. No special treatment can be given to the assessee. Furthermore, once the assessee failed to justify and substantiate the credit period of 90 days before the lower authorities, it is preposterous