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

Bench: Us :

prices less than FMV to a firm or company. The intent of legislation is to tackle transfer of shares and not the cases of primary allotment of the share. c) The assessee entered into an understanding with Kineta Global Limited and their promoters on 18-02-2010 for investing Rs. 50 crores for acquiring not less than 51% of Kineta

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA; (v) any transaction, referred to in any other section under Chapter VI- A or section 10AA, to which provisions of sub-section

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

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

Bench: Us:

22 Sanghi Textiles Privarte Limited vs. ITO filed by the assessee in response to notice under section 148 of the Act, the AO, before proceeding to decide the controversy with regard to the escaped assessment, is mandatorily required to issue notice under section 143(2) of the Act. Also, a similar view had been taken by the Hon’ble High

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

NATEMS SOLAR POWER PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD 16(1), HYDERABAD

Bench: Us:

section 92CB of the Act and Rule 10TD, providing for Safe Harbour Rules. Safe Harbour Rules provide for certain circumstances, where the transfer price declared by an eligible assessee in respect of the specified international transactions, shall be accepted to be at arm’s length by the tax authorities. The said rules recognizes above position that loans denominated in different

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

Bench: Us:

2) of Section 92F, where the goods or services are transferred in specified domestic transactions referred to in Section 92BA of the Act. We are of the firm conviction that now when the chilling units (i.e., eligible units) had carried out the inter-unit transfer of milk to the processing units considering the “market value” of the subject goods, which

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

transfer pricing adjustment qua the provision of IT services. 3. When the assessee filed objections before the learned DRP, learned DRP, while confirming the disallowance of deduction under section 80G of the Act, issued certain directions. Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

transfer pricing adjustment qua the provision of IT services. 3. When the assessee filed objections before the learned DRP, learned DRP, while confirming the disallowance of deduction under section 80G of the Act, issued certain directions. Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1,, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

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

Bench: Us.

Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section (2), an order

INTERWRAP CORP PRIVATE LIMITED (SUCCESSOR OF OWENS CORNING INDUSTRIES (INDIA) PRIVATE LIMITED),MUMBAI vs. DCIT., CIRCLE -5(1), HYDERABAD

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)

section 1448 of the Income-tax Act pursuant to the directions dated 14 June 2022 by Dispute Resolution Panel, Bangalore (DRP) u/s 144C(5) of the Act, is bad in law and void ab initio so far as it is prejudicial to the Appellant. Transfer Pricing Adjustment 2. That on the facts and circumstances of the case

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

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

transfer pricing adjustment.” 2. Also, the assessee company has raised the following additional ground of appeal, which reads as under: “Ground No.15. On the facts and in the circumstance of the case and in law, the Ld. AO has erred in passing impugned order which is barred by limitation and void ab initio and is liable to be quashed