ADP PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

In the result, ground of appeal No

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singhassessment Year:2014-15

Transfer Pricing Officer, however, the assessee raised objections against selection of this company before the DRP as well as before us. The grievance of the assessee is, the company being involved in development of products and since no segmental details are available in the annual report, it cannot be treated as comparable. The Co-ordinate Bench in Tech Mahindra

GORLAS INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER ,WARD 2(4), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

price paid or promised or part- paid and part-promised. Sale how made. Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion or other intangible thing, can be made only by a registered instrument. In the case of tangible immoveable property of a value

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

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 segment and Rs.8,93,558/- on account of interest on trade receivables. Accordingly, the Ld. AO passed the draft assessment order under

OPEN TEXT TECHNOLOGIES INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

price. 15. Infosys Ltd. The learned AR of the assessee has submitted that as per the financials of this company, it provides solutions that span the entire software life cycle encompassing consulting, design, development, re-engineering, maintenance systems integration, package evaluation and implementation. In addition, the company develops/owns proprietary products like Finacle, Infosys m-Connect. It has also earned revenue

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

In the result, assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singhassessment Year: 2014-15 M/S Dst Worldwide Services Dcit, Circle 17(1) India Private Limited Vs. Hyderabad 5Th Floor, Block B Q City Survey # 109, 110, 111/2 Nanakramguda Village Serilingampally Mandal Gachibowli Rr Dist. Hyderabad 500 032 Pan: Aaac17097L (Appellant) (Respondent) Sh. Aliasger Rampurwala, Ar Asessee By: Revenue By: Smt. Anjala Sahu, D.R. Date Of Hearing: 02/09/2020 Date Of Pronouncement: 30/09/2020 Order Per Smt. P. Madhavi Devi, J.M. This Is Assessee’S Appeal For The A.Y. 2014-15 Against The Final Assessment Order Dated 31.10.2018 Passed U/S 143(3) R.W.S. 92Ca(3) & 144C(13) Of The I.T. Act, 1961. This Appeal Was Taken Up For Hearing On 02.09.2020 Through Video Conferencing & Both The Parties Were Heard.

Pricing documentation; b. applying/modifying certain filters while undertaking comparability analysis; 4. On the facts and in the circumstances of the case and in law, Ld. AO / Ld. TPO/ Hon'ble DRP erred in including following companies 3 ITA No.2234/Hyd/2018 AY 2014-15 M/s DST Worldwide Services India P Ltd. Hyd. in the comparable set which are not comparable

RAIN CEMENTS LIMITED, HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2008-09 M/S. Rain Cements Ltd Vs. Dy. Commissioner Of (Formerly Known As Rain Income Tax, Circle 3 (1) Cii Carbon (India) Ltd Hyderabad Hyderabad Pan:Aabcr8858F (Appellant) (Respondent) Assessee By: Advocate Prathishta Singh & Advocate Deepak Chopra Revenue By: Dr.Rajendra Kumar, Cit-Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 24.03.2017 Passed U/S 143(3) R.W.S. 144C(5) R.W.S. 260 Of The I.T. Act For The A.Y 2008-09. 2. This Appeal Was Earlier Decided By The Tribunal Vide Order Dated 18.10.2019. Subsequently Vide Ma No.15/Hyd/2020, Dated 23.3.2021, The Tribunal Recalled The Entire Order For Fresh Adjudication. Therefore, This Is A Recalled Matter.

transfer pricing adjustment is concerned, he submitted that a calculation error has been pointed out identifying the escaped income at INR 29,87,704/- which relates to the corporate guarantee fee which has been computed by the TPO. He submitted that the TPO had made the adjustment on the basis of the quantum of the corporate guarantee taking into account

SRINI PHARMACEUTICALS LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(2), HYDERABAD, HYDERABAD

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

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2010-11 Srini Pharmaceuticals Ltd., Vs. Dy. Commissioner Of Income- Hyderabad. Tax, Circle – 3(2), Hyderabad.

Transfer Pricing Officer (TPO) as per the provisions of section 92CA for determination of Arm’s Length Price. Accordingly, the case was referred to the TPO for determination of Arm’s Length Price with the prior approval of the CIT-III, Hyderabad. 4.1 Assessee’s Profile: The assessee, Srini Pharmaceuticals Ltd., was incorporated under the Companies Act, 1956, on 24th

HYDERABAD INFRATECH PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, assessee’s appeal is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2014-15

transfer pricing documentation maintained by the Appellant by invoking provisions of sub-section (3) of 92CA of the Act. 3. The learned AO/ learned TPO/ Hon'ble DRP erred in re- characterizing the Fully & V Compulsory Convertible Debentures ("FCCDs") issued by the Appellant to its Associated Enterprise ("AE") as a loan. 4. The learned AO/learned TPO/Hon'ble DRP erred

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

In the result, appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year:2014-15

247 2014-15 41,23,17,354 2015-16 41,09,92,024 2016-17 39,53,90,897 2017-18 37,55,95,589 2018-19 38,93,10,570 2019-20 51,87,19,877 2020-21 58,73,44,657 28. In our opinion, the transfer of IP from Blujay India to Blujay UK cannot question

ANIRUDH VENKATA RAGI ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(2), HYDERABAD

In the result, appeal of the assessee is dismissed

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

prices of shares of certain companies listed on the Bombay Stock Exchange (BSE), with the basic object to convert black money into white, without payment of any taxes thereon. She further recorded that the Securities and Exchange Board of India (SEBI) identified some manipulators of share market by considering inputs from the income tax department and its own surveillance system

SHANKAR LAL AGARWAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-16(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri K. Narasimha Chary

transfer is complete in accordance with the provisions of Section 45 of the Act. Her case is that the provisions of Section 45 of the Act, mentions clearly that the capital gain shall be the consideration received as reduced by the cost of acquisition of the capital asset and the capital gain is correctly worked out by the assessee

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

transfer pricing adjustment u/s. 92C of the Act, Rs. 1,84,86,811/- on account of disallowance of excess provisions, Rs.7,14,84,000/- on account of addition u/s. 41(1) & 41(4A) of the Act, Rs.6,56,45,600/- on account of disallowance u/s. 40(a)(ia) of the Act and Rs.34,29,453/- on account of disallowance

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

transfer pricing adjustment u/s. 92C of the Act, Rs. 1,84,86,811/- on account of disallowance of excess provisions, Rs.7,14,84,000/- on account of addition u/s. 41(1) & 41(4A) of the Act, Rs.6,56,45,600/- on account of disallowance u/s. 40(a)(ia) of the Act and Rs.34,29,453/- on account of disallowance

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

transfer pricing adjustment u/s. 92C of the Act, Rs. 1,84,86,811/- on account of disallowance of excess provisions, Rs.7,14,84,000/- on account of addition u/s. 41(1) & 41(4A) of the Act, Rs.6,56,45,600/- on account of disallowance u/s. 40(a)(ia) of the Act and Rs.34,29,453/- on account of disallowance

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

transfer pricing adjustment u/s. 92C of the Act, Rs. 1,84,86,811/- on account of disallowance of excess provisions, Rs.7,14,84,000/- on account of addition u/s. 41(1) & 41(4A) of the Act, Rs.6,56,45,600/- on account of disallowance u/s. 40(a)(ia) of the Act and Rs.34,29,453/- on account of disallowance

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

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

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2014-15 M/S. Kony India Private Vs. Deputy Commissioner Of Limited, Income Tax, Sez Unit Ii, Office Level-7, Circle-2(1), Building No. Ho6, Phoenix Room No.514, 5Th Floor, Info City Private Limited, Signature Towers, Opp. Serilingampally, Hyderabad Botanical Garden, – 500 081. Kondapur, Hyderabad-84. Pan: Aadck 2294 C (Appellant) (Respondent) Assessee By: Sri H. Srinivasulu & Sri Kranthi Palivela Ca, Ars Revenue By: Sri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 26/08/2019 Date Of Pronouncement: 20/11/2019

Section 212 of the Companies Act,1956 for the summary financial performance of our subsidiaries. The audited financial statements and related information of subsidiaries will be available on our website,www.infosys.com.” Extraction from page 349 of PB-II 2.10.1 Investment in Lodestone Holding AG On October 22, 2012, Infosys acquired 100% of the outstanding share capital of Lodestone Holding

KAMLESH KONODIA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-11(2), HYDERABAD

Appeal is treated as allowed for statistical purposes

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

Section 50C for making long term capital gain addition of Rs.25,20,247/- involving the assessee’s half share coming to Rs.12,60,124/-. There is no dispute qua the basic fact that the assessee had indeed transferred capital asset i.e., an area measuring 400 sq. yds., from plot No.14 and 28 sq. yds., from plot No.15; in the relevant

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

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

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

price which amounted to Rs.17,73,99,815/-. The assessee, however, did not make disclosure of Rs.9,73,00,780/- only in respect of Haritavanam Project after adjusting the cash expenditure of Rs.8,00,99,035/-. In absence of any evidence towards the cash expenditure made addition of Rs.62,20,540/- to the total income of the assessee

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

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

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

price which amounted to Rs.17,73,99,815/-. The assessee, however, did not make disclosure of Rs.9,73,00,780/- only in respect of Haritavanam Project after adjusting the cash expenditure of Rs.8,00,99,035/-. In absence of any evidence towards the cash expenditure made addition of Rs.62,20,540/- to the total income of the assessee