ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Transfer Pricing Officer (TPO) in respect of specified domestic transactions reported by the assessee company. The TPO, after examining the submissions and documentation furnished by the assessee company, passed an order under section 92CA(3) of the Act, determining the arm's length price (ALP) of the specified domestic transactions and did not propose any adjustment. 4. Thereafter

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Transfer Pricing Officer\n(TPO) in respect of specified domestic transactions reported by the\nassessee company. The TPO, after examining the submissions and\ndocumentation furnished by the assessee company, passed an order\nunder section 92CA(3) of the Act, determining the arm's length price\n(ALP) of the specified domestic transactions and did not propose any\nadjustment.\n4.\nThereafter

THERMODYNE DYNAMICS PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD -17(3), HYDERABAD

Bench: Us :

14A r.w. Rule 8D(2)(iii) of Rs.15.75 lacs. 4 Thermodyne Dynamics Private Limited Vs. ITO 4. On a perusal of the record, the A.O. further observed that the assessee company had during the subject year acquired 3,15,00,000 shares of M/s. Kineta Global Limited at a face value of Rs.10/- each. On verification, the A.O. observed that

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

2. On the facts and in the circumstances of the case and in law, the Ld. Panel erred in upholding the action of the Ld. Transfer Pricing Officer ('Ld. TPO')/Ld. AO in proposing an adjustment of INR 19,43,26,338 to the specified domestic transactions ('SDTs') pertaining to inter-unit transfer of milk. 3. On the facts

CHINTALAPATI HOLDINGS PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD

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

price and sale consideration in respect of such shares transacted Page 3 of 22 ITA No. 385 & 386/Hyd/2015 by the assessee, to the income of the assessee which was Rs. 3,69,55,200/-. 8. Aggrieved by the additions, assessee preferred appeal before the learned CIT(A). Insofar as the income from house property is concerned, learned CIT(A) directed

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

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

price and sale consideration in respect of such shares transacted Page 3 of 22 ITA No. 385 & 386/Hyd/2015 by the assessee, to the income of the assessee which was Rs. 3,69,55,200/-. 8. Aggrieved by the additions, assessee preferred appeal before the learned CIT(A). Insofar as the income from house property is concerned, learned CIT(A) directed

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

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

price and sale consideration in respect of such shares transacted Page 3 of 22 ITA No. 385 & 386/Hyd/2015 by the assessee, to the income of the assessee which was Rs. 3,69,55,200/-. 8. Aggrieved by the additions, assessee preferred appeal before the learned CIT(A). Insofar as the income from house property is concerned, learned CIT(A) directed

BRIGHTCOM GROUP LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

2) of the Act was issued on 17.07.2017. In view of involvement of international transactions, the matter was referred to the Learned Transfer Pricing Officer (“Ld. TPO”) under section 92CA of the Act for determining the arm’s length price. The Ld. TPO, vide order dated 30.10.2018, proposed an adjustment of Rs.6,97,67,380/- on account of software development

LYCOS INTERNET LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

transfer pricing proceedings and were\nfound to be at Arms' Length and therefore, it is apparent that the\nAssessing Officer has conducted a thorough inquiry on all these\nissues including the issue of the income of US entity reported in\nthe consolidated and standalone financial statements as per of\nthe annual report. Once all the relevant record was available\nbefore

DY. COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), HYDERABAD vs. UNION BANK OF INDIA, HYDERABAD

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

14A r.w.r 8D is not applicable when shares are held as stock-in-trade by a Bank. Although we are unable to agree with the said argument of the learned Counsel for the assessee, but to give another opportunity to the assessee to explain its case before the Assessing Officer in light of the decision of the Hon'ble Supreme

UNION BANK OF INDIA,HYDERABAD vs. DY. COMMISSISONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

14A r.w.r 8D is not applicable when shares are held as stock-in-trade by a Bank. Although we are unable to agree with the said argument of the learned Counsel for the assessee, but to give another opportunity to the assessee to explain its case before the Assessing Officer in light of the decision of the Hon'ble Supreme

MYLAN LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result. appeal of the Assessee is partly\nallowed for statistical purposes and appeal of Revenue is\npartly allowed for statistical purposes

Transfer Pricing Officer [in short “TPO"] for\ndetermination of the Arms Length Price [in short “ALP”] of\ninternational transactions of the appellant company with it's\nAEs.\n3.1.\nDuring the course of TP proceedings, the TPO\nnoticed that, as per Form-3CEB report, the appellant\ncompany has reported various international transactions\nwith its AEs for purchase of raw materials, sale

CAMBRIDGE TECHNOLOGY ENTERPRISES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result assessee’s appeal stand partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

Transfer Pricing Documentation as per section 92C of the Act and Rule 10D of the IT Rules by complying all the provisions of the section. 2.4. Erred in rejecting the TP Documentation maintained by the assessee without assigning any cogent reasons for rejection. 2.5. Erred in not appreciating the fact that TP Documentation is not an exact science and arriving

ADAMA INDIA PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(3), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2014-15 Adama India Pvt. Ltd., Vs. Income-Tax Officer, Hyderabad. Ward – 1(3), Hyderabad. Pan – Aabcm 09294F (Appellant) (Respondent) Assessee By : Shri Raghunathan S. Revenue By : Shri Y.V.S.T. Sai Date Of Hearing : 09-04-2019 Date Of Pronouncement : 03-07-2019 O R D E R

transfer pricing ('TP') documentation and the economic analysis undertaken by the Appellant without any robust reasons to determine the arm's length price (' ALP') for receipt of management services. 4.2 On the facts and in the circumstances of the case and in contrary to law, the ld. AO/ld. TPO erred in not satisfying any of the conditions prescribed

NEOVANTAGE INNOVATION PARK PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD 16(3), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

2) of the Income Tax Act, 1961 (“the Act”) was issued on 29.06.2021. In view of involvement of international transactions, the matter was referred to the Learned Transfer Pricing Officer (“Ld. TPO”) under section 92CA of the Act for determining the arm’s length price. The Ld. TPO, vide order dated 30.12.2022, proposed an adjustment of Rs.13

NEOVANTAGE BIO-TECHNOLOGY PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE 5(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

2) of the Income Tax Act, 1961 (“the Act”) was issued on 29.06.2021. In view of involvement of international transactions, the matter was referred to the Learned Transfer Pricing Officer (“Ld. TPO”) under section 92CA of the Act for determining the arm’s length price. The Ld. TPO, vide order dated 30.12.2022, proposed an adjustment of Rs.13

MY HOME INDUSTRIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.289/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) My Home Industries Vs. Dy.Cit Private Limited, Hyderabad Circle 5(1) Pan: Aabcm9480C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 28/10/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By My Home Industries Private Limited, (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.01.2024 For The A.Y 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:

2 of 22 ITA No 289 of 2024 My Home Industries P Ltd the matter to the Learned Transfer Pricing Officer (“Ld. TPO”) under section 92CA(1) of the Act for determination of the Arm’s Length Price (“ALP”). 3.1 During the proceedings before the Ld. TPO, it was observed by the Ld. TPO that the assessee had made captive

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX , HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

2(24) of Income Tax Act, 1961 and when a receipt is not on in the character of income it cannot form part of the book profit under Section 115JB of the Act, 1961. In the case of AppolloTyres Ltd. (supra) the income in question was taxable but was exempt under a specific provision of the Act as such

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

2(24) of Income Tax Act, 1961 and when a receipt is not on in the character of income it cannot form part of the book profit under Section 115JB of the Act, 1961. In the case of AppolloTyres Ltd. (supra) the income in question was taxable but was exempt under a specific provision of the Act as such