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

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

In the result, the appeals filed by the assessee is partly allowed\nfor statistical purposes

sections": ["92CA(3)", "144C", "143(3)", "37(1)", "40(a)(ii)", "10B(1)(e)", "234B", "234D"], "issues": "The primary issue in this appeal revolves around the determination of the Arm's Length Price (ALP) for software development services. This includes challenges to the transfer

REPAL RENEWABLES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

transfer pricing adjustment. Payment for consultancy services availed 3. On the facts and circumstances of the case and in law, the Id. AO and the Ld. TPO, under the directions of the Hon'ble DRP, erred in disregarding the Appellant's benchmarking analysis, the documentation maintained thereunder and determining the arm's length price of the transaction of Payment

REPAL RENEWABLES PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

transfer pricing adjustment. Payment for consultancy services availed 3. On the facts and circumstances of the case and in law, the Id. AO and the Ld. TPO, under the directions of the Hon'ble DRP, erred in disregarding the Appellant's benchmarking analysis, the documentation maintained thereunder and determining the arm's length price of the transaction of Payment

DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD vs. AZINGO SOFT SYSTEMS INDIA PVT. LTD., HYD, HYDERABAD

In the result, the grounds of the assessee are allowed for statistical purposes

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

transfer pricing adjustment in respect of international transaction with AE. Selection of uncomparable companies 6. That on the facts and circumstances of the case and in law, the AO /DRP erred in accepting following companies as comparable companies as selected by the TPO: a) E-Infochips Bangalore Ltd; b) Kals Information Systems Ltd; c) E-Zest Solutions Ltd; d) Tata

AZINGO SOFT SYSTEMS (INDIA) PVT.LTD., HYD,SECUNDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD

In the result, the grounds of the assessee are allowed for statistical purposes

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

transfer pricing adjustment in respect of international transaction with AE. Selection of uncomparable companies 6. That on the facts and circumstances of the case and in law, the AO /DRP erred in accepting following companies as comparable companies as selected by the TPO: a) E-Infochips Bangalore Ltd; b) Kals Information Systems Ltd; c) E-Zest Solutions Ltd; d) Tata

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

234D of the Act while calculating the Appellant's\npayable demand.\nInitiation of penalty under Section 270A\n11. On the facts and circumstances of the case and in law, the Id. AO\nerred in initiating penalty proceedings under Section 270A of the\nAct.\n5\nITA.Nos.125 & 474/Hyd./2022\nThe above grounds are independent and without prejudice to one\nanother

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

transfer pricing adjustment. 3 ITA.Nos.125 & 474/Hyd./2022 Payment for consultancy services availed 3. On the facts and circumstances of the case and in law, the Id. AO and the Ld. TPO, under the directions of the Hon'ble DRP, erred in disregarding the Appellant's benchmarking analysis, the documentation maintained thereunder and determining the arm's length price

CORDYS SOFTWARE INDIA PVT.LTD., (NOW MERGED WITH OPEN TEXT CORPN. INDIA P. LTD),HYDERABAD vs. DCIT, CIR-1(2), HYD, HYDERABAD

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

Bench: Smt P. Madhavi Devi & Shri B. Ramakotaiahassessment Year: 2011-12 Open Text Corporation Vs. Dy. Cit, Circle-1(2), India Pvt Ltd., (Cordys Hyderabad. Software India Pvt Ltd Is Now Merged With Open Tex Corporation India Pvt Ltd.,) Hyderabad. Pan- Aaacb8264E

section 234B and 234D of the Act on the Transfer Pricing adjustment. 3. Imposing penalty u/ s 271(1)( C ) of the Act 3. Brief

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

transfer pricing provisions and the Hon'ble DRP has further erred in upholding the action of Ld. TPO/AO. 1.4 That on the facts and in the circumstances of the case and in law, the Ld. TPO/Ld. AO has erred in disregarding the judicial precedent of the Hon'ble Income-Tax Appellate Tribunal (ITAT), Hyderabad in the case of Adama India

ST. JUDE MEDICAL INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(2),, HYDERABAD

In the result, assessee’s grounds of appeal No

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmanst. Jude Medical India Pvt. Vs Dy. Commissioner Of Income Ltd, Hyderabad Tax, Circle 3 (2) Pan: Aaics 9821 J Hyderabad (Appellant) (Respondent)

transfer price adjustment of Rs.2,55,97,663 to the Total Income of the Appellant. 2. That on the facts and circumstances of the case and in law, the Dispute Resolution Panel (DRP)/ the TPO/the AO erred in not following the directions of the Hon'ble Tribunal vide order dated Page

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

transferred to unclaimed liabilities account. The assessee, during the appellate proceedings furnished the details of these unclaimed liabilities as additional evidence and the same was sent to Assessing officer for factual report. However, till date no report is received. 7.1 On perusal of the details furnished it is seen that in case of many entries there is not even