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

Transfer Pricing Grounds (i.e Ground 1 to 11) 13. Non-grant of MAT credit available to the Company. Without prejudice to the above grounds, that on facts and circumstances of the case, the Ld. AO has grossly erred in law as well as in facts, in non-grant of MAT Credit available, amounting

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

Transfer Pricing Grounds (i.e Ground 1 to 11) 13. Non-grant of MAT credit available to the Company. Without prejudice to the above grounds, that on facts and circumstances of the case, the Ld. AO has grossly erred in law as well as in facts, in non-grant of MAT Credit available, amounting

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)

transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 5,08,183. 8 ADP Private Limited b) Not appreciating that the receivables are consequential/closely linked to the principal transaction of provision of services and hence have been aggregated for determination of Arm's Length Price ('ALP') under Transactional Net Margin Method ('TNMM'). c) Not appreciating

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

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)

transfer pricing adjustment of Rs. 6,06,64,733/- in respect of international transactions pertaining to software development services. 4. Thereafter, the A.O. has passed the draft assessment order under Section 144C(1) of the Income-tax Act, 1961 on 20.09.2023, determining the total income after considering the TP adjustment proposed by the Ld. TPO. In the draft order

SAXON GLOBAL INDIA PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

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

transfer pricing study of the assessee company without providing any cogent reasons. under the facts and circumstances of the case. b. The authorities below erred in rejecting the comparables selected by the assessee merely for the reason that the companies did not appear in TPO search universe although such comparables were appropriate for comparison under the facts and circumstances

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

transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 1,23,24,559. 16. On the fact, and circumstances of the case and in contrary to law, the addition made by the Ld. TPO with respect to interest on outstanding receivables is untenable and be deleted since the addition has been made by computing interest

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

transfer pricing adjustment in the nature of notional interest on receivables amounting to Rs. 1,23,24,559. 16. On the fact, and circumstances of the case and in contrary to law, the addition made by the Ld. TPO with respect to interest on outstanding receivables is untenable and be deleted since the addition has been made by computing interest

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

234A / 234B (Tax Effect: ₹1,33,82,860/-) 7.1. Interest wrongly levied. 8. Penalty Proceedings 8.1. Penalty initiated under Section 274 r.w.s. Section 270A is bad in law.” 3. The brief facts of the case are that the assessee, CallidusCloud India Private Limited, is engaged in the business of providing sales support, marketing and consulting services and software development

INFOR INDIA PRIVATE LIMITED (FORMERLY KNOWN AS INFOR GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman, Accountant Memebr Assessment Year: 2012-13 Infor (India) Pvt. Ltd., Vs. Dy. Commissioner Of (Formerly Known As Infor Income-Tax, Hyderabad. Global Solutions (India) Pvt. Ltd.), Hyderabad Pan – Aaacb6197Q Appellant Respondent Assessee By: Shri Sunil Motilala Revenue By: Shri Yvst Sai

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. 14. On the facts and in the circumstances of the case and in law, the Ld. AO, Ld. TPO erred in and the Hon'ble DRP further erred in upholding

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

Appeal is partly allowed in above terms

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

transfer pricing analysis/ study prepared by the Appellant and conducting fresh benchmarking, without appreciating that none of the conditions mentioned in clauses (a) to (d) of Section 92C(3) of the Act were satisfied. SOFTWARE DEVELOPMENT SERVICES (SDS) SEGMENT 3. On the facts and in the circumstances of the case and in law, the Ld.TPO erred

PURPLETALK INDIA PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-9(1), HYDERABAD

sections": [ "143(3)", "144C(13)", "143(3A)", "143(3B)", "92CA", "92C(3)", "92D(1)", "10B", "36(1)(va)", "2(24)(x)", "37(1)", "234A", "234B", "234C", "115JB" ], "issues": "Whether the assessee's transfer pricing

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 issue were verified and found acceptable. Despite this, the final computation mechanically adopted the total income as per intimation u/s.143(1) of the Act, including the disallowance of exemption claimed u/s.10AA of the Act. Accordingly, we set aside the issue to the file of Ld. AO to reconsider the claim of the assessee ITA No.912/Hyd/2024 28 and decide

SGB BRANDSAFWAY PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

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

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

Transfer Pricing Officer (“Ld. TPO”). The Ld. TPO vide his order dated 29.01.2021 suggested upward adjustment of Rs.63,50,009/-. Accordingly, the Ld. AO passed the draft assessment order on 30.03.2021. 3. Aggrieved with draft assessment order passed by Ld. AO, the assessee preferred objections before the Ld. DRP. In pursuant to the direction of the Ld. DRP dated

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

transfer of a long-term capital asset (other than a residential house) is invested in the purchase or construction of one residential house within the prescribed time limits. The \"cost of the new asset includes both the purchase price and the cost of construction or improvement of the residential house. The Assessing Officer accepted the purchase price paid

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

234A, 2348 and 234C of the Act, under the facts and circumstances of the case. 11. The Appellant craves leave to add, alter, delete or substitute any of the grounds urged above. 4 ITA.No.1527 & 1528/Hyd./2025 12. In the view of the above and other grounds that may be urged at the time of the hearing of the appeal

WISSEN INFOTECH PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSSIONER OF INCOME TAX ,CIRCLE-17(2) , HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

234A, 234B and 234C of the Act against legally untenable adjustment.” 3. The grounds raised by the assessee for A.Y. 2016-17 read as under : “1. The The Learned Assessing Officer / Ld Dispute Resolution Panel (DRP) are erroneous in law and on the facts of the case. 2. The Ld DRP/AO ought to have accepted the Profit margin

WISSEN INFOTECH PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

234A, 234B and 234C of the Act against legally untenable adjustment.” 3. The grounds raised by the assessee for A.Y. 2016-17 read as under : “1. The The Learned Assessing Officer / Ld Dispute Resolution Panel (DRP) are erroneous in law and on the facts of the case. 2. The Ld DRP/AO ought to have accepted the Profit margin

ASST.COMMISSIONER OF INCOME TAX (EXEMPTIONS), HYDERABAD vs. NALGONDA DIOCESE SOCIETY, NALGONDA

Appeal is dismissed

Bench: Shri A. Mohan Alakamony, A.M. & Shri S.S.Godara, J.M.

price and upon such terms, conditions and rates of interest.” 3. Ld.D.R. vehemently contended during the course of hearing that the CIT(A) has erred in law and on facts in treating the assessee eligible for sec.11 exemption thereby holding that no transfer of its asset in favour of M/s Diocese Society had ever taken place. We find no merit