ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order dt.31.03.2015 wherein at Page 3, the Assessing Officer has mentioned as under : Zuari Cement Limited, Kadapa “The assessee debited

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order dt.31.03.2015 wherein at Page 3, the Assessing Officer has mentioned as under : Zuari Cement Limited, Kadapa “The assessee debited

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

TRANSFER PRICING ISSUES. Firstly, we will deal with ground Nos. 5(a) and 5(b): With respect to grounds 5(a) and 5(b) for A.Y. 2011-12, the ld. AR had drawn our attention to the draft assessment order dt.31.03.2015 wherein at Page 3, the Assessing Officer has mentioned as under : Zuari Cement Limited, Kadapa “The assessee debited

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

transfer pricing adjustment. He further submitted that, the assessee had entered into a Bilateral Advance Pricing Agreement (“BAPA”) u/s.92CC of the Act, which cover the assessment year under consideration and in the light of the BAPA, the assessee seeks the withdraw ground no.1. Accordingly, the Ld. AR invited our attention to the withdrawal request of ground no.1 placed at page

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

Bench: Us:

Section 143(3) r.w.s 144C(13) r.w.s 144B of the Act, dated 25.02.2024, has carried the matter in appeal before us. 9. We have heard the Ld. Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them

INFOR (INDIA) PRIVATE LIMITED (FORMERLY KNOWN INFOR GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

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

transfer pricing provisions. 5. On the facts and in the circumstances of the case and i 0 Jaw. the Ld. TPO and the Ld, AO erred in bringing notional interest to tax without considering the fact that neither the AE nor the Appellant charges any interest in case of delay in payment LEVY OF INTEREST UNDER SECTION 234(3

INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRLCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

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

transfer pricing provisions. 5. On the facts and in the circumstances of the case and i 0 Jaw. the Ld. TPO and the Ld, AO erred in bringing notional interest to tax without considering the fact that neither the AE nor the Appellant charges any interest in case of delay in payment LEVY OF INTEREST UNDER SECTION 234(3

FACEBOOK INDIA SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 Facebook India Online Services Vs. The Deputy Commissioner Private Limited, Of Income Tax, 12Th Floor, Building No.20, Circle – 17(1), Unit 1203 & 1204, Hitech City, Hyderabad. Madhapaur, Hyderabad. Pan : Aabcf5150G. (Appellant) (Respondent) Assessee By: Shri Dhanesh Bafna & Chandni Shah Revenue By: Shri Rajendra Kumar – Cit-Dr Date Of Hearing: 20.07.2022 Date Of Pronouncement: 19.09.2022

Section 271(1)(C) of the Act. It is prayed that the Ld. AO be directed to drop the penalty proceedings initiated u/s 271(1)(C) of the Act.” 2. The brief facts of the case are that assessee company is engaged in the business of Service Sector, IT Enabled Services and BPO Providers, back office support services

ACIT, CIRCLE-2(1), HYDERABAD vs. Y S JAGAN MOHAN REDDY, KADAPA

In the result, cross objection filed by the assessee is\nallowed

price at Rs.800/- per share after\ntaking into account the value of the shares of M/s Sandur\nPower Company Ltd.\n11. The appellant craves leave to, add to, amend or\nmodify the above grounds of appeal either before or at the\ntime of hearing of he appeal, if it is considered necessary.\n3. The brief facts of the case

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

In the result, appeal of the assessee is partly allowed

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

Price (ALP). The TPO, vide his order u/s 92CA(3) dated 31.10.2017, warranted no adjustment and therefore the TP addition was ‘nil’. 3.2. During the assessment proceedings u/s 143(3) r.w.s. 92CA(3) of the I.T. Act 1961, the AO noticed from the Annual Report for the F.Y. 2013-14, that the Assessee company had charged Rs.141

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

In the result, appeal of the assessee is partly allowed

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

Price (ALP). The TPO, vide his order u/s 92CA(3) dated 31.10.2017, warranted no adjustment and therefore the TP addition was ‘nil’. 3.2. During the assessment proceedings u/s 143(3) r.w.s. 92CA(3) of the I.T. Act 1961, the AO noticed from the Annual Report for the F.Y. 2013-14, that the Assessee company had charged Rs.141

AUROBINDO PHARMA LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.172/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2019-20) Aurobindo Pharma Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aabca7366H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri B.G. Reddy, Advocate राज" व "ारा/Revenue By:: Smt. M Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/01/2025 घोषणा की तारीख/Pronouncement: 19/02/2025 आदेश/Order

Transfer Pricing Grounds: A. On disallowance of weighted deduction U/s 35(2AB): 1. The Learned DRP/Assessing Officer erred in law and on facts and circumstances of the case in not allowing weighted deduction under section 35(2AB) of the Income Tax Act, 1961 in respect of expenditure incurred in connection with Clinical Trials/ Bio-Analytical and Bio- Equivalence studies without

SYNCHRONY INTERNATIONAL SERVICES PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE -3(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.2071 To 2073 /Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2018-19) Synchrony International Vs. Assistant Commissioner Services Private Limited Of Income Tax Hyderabad Circle 3 (2) Pan: Aadcr9682D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Aliasgar Rampurwala, Ca राज" व "ारा/Revenue By:: Shri Aves Madhukar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/03/2026 घोषणा की तारीख/Pronouncement: 30/03/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

transfer pricing adjustment of Rs.26,24,06,156/- and also disallowance of Rs.4,46,617/- under section 43B of the Act on account of delayed payment of provident fund. The assessee, vide letter dated 06.01.2020, submitted a no objection letter and requested for passing of the final assessment order. Accordingly, the Ld. AO passed the final assessment order under section

SYNCHRONY INTERNATIONAL SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE- 3(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.2071 To 2073 /Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2018-19) Synchrony International Vs. Assistant Commissioner Services Private Limited Of Income Tax Hyderabad Circle 3 (2) Pan: Aadcr9682D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Aliasgar Rampurwala, Ca राज" व "ारा/Revenue By:: Shri Aves Madhukar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/03/2026 घोषणा की तारीख/Pronouncement: 30/03/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

transfer pricing adjustment of Rs.26,24,06,156/- and also disallowance of Rs.4,46,617/- under section 43B of the Act on account of delayed payment of provident fund. The assessee, vide letter dated 06.01.2020, submitted a no objection letter and requested for passing of the final assessment order. Accordingly, the Ld. AO passed the final assessment order under section

SYNCHRONY INTERNATIONAL SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 3(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.2071 To 2073 /Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2018-19) Synchrony International Vs. Assistant Commissioner Services Private Limited Of Income Tax Hyderabad Circle 3 (2) Pan: Aadcr9682D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Aliasgar Rampurwala, Ca राज" व "ारा/Revenue By:: Shri Aves Madhukar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/03/2026 घोषणा की तारीख/Pronouncement: 30/03/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

transfer pricing adjustment of Rs.26,24,06,156/- and also disallowance of Rs.4,46,617/- under section 43B of the Act on account of delayed payment of provident fund. The assessee, vide letter dated 06.01.2020, submitted a no objection letter and requested for passing of the final assessment order. Accordingly, the Ld. AO passed the final assessment order under section

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

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

transferred by the assessee to its subsidiaries during the year were working capital advances, which were later decided to be treated as investments, then the T.P. adjustment already made by the AO shall be revived and the assessment shall be completed accordingly.” 3. Mr. Sai fails to pin-point any distinction on the relevant facts involved in all these assessment

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

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

transferred by the assessee to its subsidiaries during the year were working capital advances, which were later decided to be treated as investments, then the T.P. adjustment already made by the AO shall be revived and the assessment shall be completed accordingly.” 3. Mr. Sai fails to pin-point any distinction on the relevant facts involved in all these assessment

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

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

transferred by the assessee to its subsidiaries during the year were working capital advances, which were later decided to be treated as investments, then the T.P. adjustment already made by the AO shall be revived and the assessment shall be completed accordingly.” 3. Mr. Sai fails to pin-point any distinction on the relevant facts involved in all these assessment