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

In the result, ground of appeal No

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singhassessment Year:2014-15

transfer pricing analysis / study prepared by the Appellant, without appreciating that none of the conditions mentioned in clauses (a) to (d) of Section 92C(3) of the Act were satisfied. 8. On the facts and in the circumstances of the case and in law, the Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming

ZETA INTERACTIVE SYSTEMS (INDIA) PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(4), HYDERABAD

Appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2011-12

section 133(6} of the Act. It appears that the TPO has not examined the services rendered by the company to give a finding whether the services performed by this company are similar to the software development services performed by the assessee. From the details on record, we find that while the assessee is into software development services, this company

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

transfer pricing analysis is an estimation and not an exact science. There is always an element of estimation and working capital adjustment must be based on opening and closing working capital deployed and daily working capital requirements data cannot be insisted upon. One has to see that reasonable adjustment be made where- ever it is needed so as to bring

HIGHRADIUS TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -2(1), HYDERABAD

Bench: Us:

Section 133 of the companies Act, 1961.” (b) The company also manufactures products such as electronic boards and printer circuits by importing raw materials and holding inventory, as apparent from Page No. 119 of the PB-II. The assessee company is not engaged into any activity of producing physical goods. Page No. 119 of the PB-II (c) The company

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 133(6) of the I.T. Act, the TPO has the power to call for the necessary details from the comparable companies. It is seen that the Assessing Officer/TPO has exercised this power to call for details with regard to the various companies. As seen from the annual report of Foursoft Limited which is reproduced at page

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 133(6) of the I.T. Act, the TPO has the power to call for the necessary details from the comparable companies. It is seen that the Assessing Officer/TPO has exercised this power to call for details with regard to the various companies. As seen from the annual report of Foursoft Limited which is reproduced at page

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

Transfer Pricing Officer (TPO) was added to the total income of the assessee. Thereafter, the ALP adjustments on account of specified domestic transactions was proposed at Rs.34,15,08,428/-. The Assessing Officer also disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280

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

Transfer Pricing Officer (TPO) was added to the total income of the assessee. Thereafter, the ALP adjustments on account of specified domestic transactions was proposed at Rs.34,15,08,428/-. The Assessing Officer also disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280

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

Transfer Pricing Officer (TPO) was added to the total income of the assessee. Thereafter, the ALP adjustments on account of specified domestic transactions was proposed at Rs.34,15,08,428/-. The Assessing Officer also disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280

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

Transfer Pricing Officer (TPO) was added to the total income of the assessee. Thereafter, the ALP adjustments on account of specified domestic transactions was proposed at Rs.34,15,08,428/-. The Assessing Officer also disallows Rs.1,88,12,419/- u/s 35(2AB) of the Act. Thus, the Assessing Officer passed the order assessing the total income at Rs.280

DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD vs. IVY COMPTECH PRIVATE LIMITED, HYD, HYDERABAD

In the result, revenue appeal is dismissed and the appeal of the assessee is partly allowed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2010-11 Dy. Commissioner Of Income- Vs. Ivy Comptech Pvt. Ltd., Tax, Circle – 2(1), Hyderabad. Hyderabad. Pan – Aaaci8884K (Appellant) (Respondent) Assessment Year: 2010-11 Ivy Comptech Pvt. Ltd., Vs. Dy. Commissioner Of Income- Hyderabad. Tax, Circle – 2(1), Hyderabad. Pan – Aaaci8884K

transfer pricing documentation requirements and disregarding the Appellant's claim for use of multiple year data for computing the arm's length price. Selection of comparables - Software segment 4. Not undertaking an objective comparative analysis and interalia selecting the following companies as comparable to the software services of the Appellant: • Comp-U-Learn Tech India Ltd; • E Infochips Bangalore

IVY COMPTECH PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-2(1), HYD, HYDERABAD

In the result, revenue appeal is dismissed and the appeal of the assessee is partly allowed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2010-11 Dy. Commissioner Of Income- Vs. Ivy Comptech Pvt. Ltd., Tax, Circle – 2(1), Hyderabad. Hyderabad. Pan – Aaaci8884K (Appellant) (Respondent) Assessment Year: 2010-11 Ivy Comptech Pvt. Ltd., Vs. Dy. Commissioner Of Income- Hyderabad. Tax, Circle – 2(1), Hyderabad. Pan – Aaaci8884K

transfer pricing documentation requirements and disregarding the Appellant's claim for use of multiple year data for computing the arm's length price. Selection of comparables - Software segment 4. Not undertaking an objective comparative analysis and interalia selecting the following companies as comparable to the software services of the Appellant: • Comp-U-Learn Tech India Ltd; • E Infochips Bangalore

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, assessee’s appeal is partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2014-15

transfer pricing analysis I study prepared by the Appellant, without appreciating that none of the conditions mentioned in clauses (a) to (d) of Section 92C(3) of the Act were satisfied. 11. On the facts and in the circumstances of the case and in contrary to law, the Ld. AO, Ld. TPO erred in and the Hon'ble DRP further

SSNC FINTECH SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

Transfer Pricing Officer [in short “TPO"] to\ndetermine the ALP of the international transactions of the\nassessee with it's AEs. During the course of TP proceedings,\nthe TPO after considering the relevant TP analysis\ndocuments submitted by the appellant-company, has\nrejected the TP documentation and has conducted a fresh\nTP study by applying certain filters

NUZIVEEDU SEEDS LIMITED,R.R.DIST. vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

In the result, all the appeals under consideration are treated as allowed for statistical purposes in above terms

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

133 of the Act. 9.3 Further, before us, the ld. DR also filed written submissions in support of revenue’s case, which are as under: “2. It is humbly submitted that the assessee is engaged in the following activities: (i) Research & Development on germplasm leading to development of hybridd seeds, which consists of two stages viz., (a) fixation of desired

NUZIVEEDU SEEDS LIMITED,R.R.DIST. vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

In the result, all the appeals under consideration are treated as allowed for statistical purposes in above terms

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

133 of the Act. 9.3 Further, before us, the ld. DR also filed written submissions in support of revenue’s case, which are as under: “2. It is humbly submitted that the assessee is engaged in the following activities: (i) Research & Development on germplasm leading to development of hybridd seeds, which consists of two stages viz., (a) fixation of desired

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD vs. NUZIVEEDU SEEDS LIMITED, R.R. DIST, HYDERABAD

In the result, all the appeals under consideration are treated as allowed for statistical purposes in above terms

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

133 of the Act. 9.3 Further, before us, the ld. DR also filed written submissions in support of revenue’s case, which are as under: “2. It is humbly submitted that the assessee is engaged in the following activities: (i) Research & Development on germplasm leading to development of hybridd seeds, which consists of two stages viz., (a) fixation of desired

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD vs. NUZIVEEDU SEEDS LIMITED, R.R. DIST, HYDERABAD

In the result, all the appeals under consideration are treated as allowed for statistical purposes in above terms

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

133 of the Act. 9.3 Further, before us, the ld. DR also filed written submissions in support of revenue’s case, which are as under: “2. It is humbly submitted that the assessee is engaged in the following activities: (i) Research & Development on germplasm leading to development of hybridd seeds, which consists of two stages viz., (a) fixation of desired