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

Bench: Us:

transfer pricing study report for benchmarking the said international transaction of provision of SDS services: •Inteq Software Pvt Ltd. •Yudiz Solutions Pvt. Ltd •R Systems International Ltd •Sasken Technologies Ltd. •Info Bears Technologies Ltd. 1.5 The learned AO erred in law and in facts in rejecting the following additional comparable companies proposed by the Appellant for 3 HighRadius Technologies Private

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

transfer pricing documentation. 6. On the facts and in the circumstances of the case and in law, the Ld. AO/Ld. TPO/Hon'ble DRP erred in rejecting certain filters applied by the Appellant. 7. On the facts and in the circumstances of the case and in law, the Ld. AO/Ld. TPO/Hon'ble DRP erred in applying certain additional filters which

MEDPLEXUS INDIA PVT. LTD., HYD,BANGALORE vs. ACIT, CIRLCE-16(2), HYD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2011-12 Medpluxes India Pvt. Ltd., Vs. Asst. Commissioner Of Income- Hyderabad. Tax, Circle – 16(2), Hyderabad. Pan – Aaecm7007N (Appellant) (Respondent) Assessee By : Shri Aliasger Rampurwala & Sri Abhiroop Bhargav Revenue By : Shri Y.V.S.T. Sai Date Of Hearing : 22-07-2019 Date Of Pronouncement : 05-09-2019 O R D E R

274 Shortfall being adjustment u/s E=C-D Rs. 33,34,083/- 92CA Accordingly, for SDS segments, the arm’s length margin was arrived at 16.93% and the arm’s length price of international transactions was determined at Rs. 5,23,41,357/- and the shortfall is computed at Rs. 33,34,083. 3.6 IT Enables Services: The TPO rejected

DSM SHARED SERVICES INDIA PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 8(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1358/Hyd/2024 Assessment Year 2021-2022 Dsm Shared Services India Private Limited, The Dcit, Circle-8(1), Hyderabad – 500 081. Hyderabad – 500 081. Vs. Telangana. Telangana. Pan Aadcd8407C (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09.12.2025 घोषणा की तारीख/Pronouncement: 12.12.2025 आदेश/Order

transfer pricing adjustment of INR 8,60,80,441 towards provision of ITes. 3 ITA.No.1358/Hyd./2024 4. On the facts and circumstances of the case and in law, the Hon'ble DRP/Ld. AO/TPO have further erred in : a. rejecting the economic analysis carried out in TP documentation which was maintained in good faith and with due diligence despite satisfying

MAHUA BHARATPUR EXPRESSWAYS LIMITED, ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

Transfer Pricing documentation were appropriate. Page 2 of 38 ITA TP Nos 67 and 493 of 2022 Western UP Tollway Ltd and ITA TP 170 of 2022 Mahua Bharatpur Expressways Ltd 4. The Hon'ble DRP/ Learned TPO/AO has grossly erred in facts and circumstances of the case and in law by: a) Determining of the arm's length price

WESTERN UP TOLLWAY LIMITED,NEW DELHI vs. DCIT CIRCLE -8(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

Transfer Pricing documentation were appropriate. Page 2 of 38 ITA TP Nos 67 and 493 of 2022 Western UP Tollway Ltd and ITA TP 170 of 2022 Mahua Bharatpur Expressways Ltd 4. The Hon'ble DRP/ Learned TPO/AO has grossly erred in facts and circumstances of the case and in law by: a) Determining of the arm's length price

WESTERN UP TOLLWAY LIMITED,NOIDA vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

Transfer Pricing documentation were appropriate. Page 2 of 38 ITA TP Nos 67 and 493 of 2022 Western UP Tollway Ltd and ITA TP 170 of 2022 Mahua Bharatpur Expressways Ltd 4. The Hon'ble DRP/ Learned TPO/AO has grossly erred in facts and circumstances of the case and in law by: a) Determining of the arm's length price

SSNC FINTECH SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

Transfer Pricing adjustment of INR 2,70,56,964/-. This adjustment was made by the Assessing Officer (AO) pursuant to directions from the Dispute Resolution Panel (DRP). The dispute revolves around the determination of the Arm's Length Price (ALP) for international transactions related to IT services provided by the assessee to its associated enterprises (AEs). The assessee's primary

APACHE FOOTWEAR INDIA PRIVATE LIMITED,MAMBATTU VILLAGE vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CIRCLE-1(1), TIRUPATI

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

274 red with section 270A, 271BA, 271AA and 271G of the Act based on Draft Assessment Order without passing a final order as required under section 144C(13) of the Income Tax Act, 1961. 3. The brief facts of the case are that assessee is a company and filed the return declaring total income at Rs. Nil. Subsequently, the case

TEK SYSTEMS GLOBAL SERVICES PRIVATE LIMITED,HYDERBAD vs. DCIT, CIRCLE-2(1), HYDERBAD

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

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.487/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2018-19) Tek Systems Global Vs. Dy. C. I. T. Services (P) Ltd, Circle 2(1) Hyderabad Hyderabad Pan:Aabcf1518Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms. K. Amulya, Ca रधजस् व द्वधरध/Revenue By:: Shri Jeevan Lal Lavidiya, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 29/05/2024 घोर्णध की तधरीख/Pronouncement: 05/07/2024 आदेश/Order

Price of the International transactions reported by the assessee. Accordingly, this amount is being added to the returned income of the assessee. The order of the TPO is made an annexure A to this Assessment Order. Penalty proceedings u/s 270A are initiated for under reporting of income. 5. The assessee has reduced his income in the revised return

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

transfer price of the Appellant’s international transactions in respect of SWD services provided by the Appellant to its AEs. 3.2. On the facts and in the circumstances of the case, the Hon'ble DRP / the Assessment Unit / learned TPO erred in: (a) Rejection of Appellant’s comparability analysis and application of additional filters: i. Selection of time period

GSS INFOTECH LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

Pricing uls 92B, as no income is generated from the transaction of providing loans and advances to the subsidiaries of the appellant company. 2.2 Erred in re-characterization of 'advance for investment' as 'Loans' which is not permissible under section 145 of the Act. 2.3 Erred in not appreciating the fact that the advances had been advanced by the appellant

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

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

Pricing uls 92B, as no income is generated from the transaction of providing loans and advances to the subsidiaries of the appellant company. 2.2 Erred in re-characterization of 'advance for investment' as 'Loans' which is not permissible under section 145 of the Act. 2.3 Erred in not appreciating the fact that the advances had been advanced by the appellant

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

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

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

transfer pricing analysis I 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. 11. On the facts and in the circumstances of the case and in contrary to law, the Ld. AO, Ld. TPO erred in and the Hon'ble DRP further

CAP GEMINI TECHNOLOGY SERVICES INDIA LIMITED(FORMERLY KNOWN AS IGATE GLOBAL SOLUTION LIMITED)-M/S PATNI TELECOM SOLUTIONS PVT LTD, CHANGED NAME TO M/S.IGATE INFORMATION SERVICES PRIVATE LIMITED MERGED WITH IGATE GLOBAL SOLUTIONS LIMITED ,HYDERABAD vs. ITO, WARD - 2(1), HYDERABAD

In the result, appeal raised by the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.446/Hyd/2015 (िनधा"रण वष"/Assessment Year: 2010-11) Cap Gemini Vs. Income Tax Officer Technology Services Ward 2(1) India Ltd(Formerly Igate Hyderabad Global Solutions Ltd) Hyderabad Pan:Aacca4255G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 04/07/2024 घोषणा की तारीख/Pronouncement: 23/07/2024 आदेश/Order

Transfer Pricing Officer resulted in selection of 19 companies as comparables and an Arm's Length Margin of 23.87% was arrived at. However, a relief was granted by the DRP to exclude Infosys Technologies Ltd. and L & T Infotech Ltd from the list of final comparables of the TPO. 3. In rejecting the objections of the assessee against the selection

GADDAM MOHAN REDDY,NIZAMABAD vs. INCOME TAX OFFICER, WARD 1, NIZAMABAD, NIZAMABAD

Bench: the AO during re-assessment proceedings.4. The authorities below further failed to appreciate that on the same set of facts, the AO with all his expertise on the provisions of the Act has allowed the deduction claimed Under Section 54F of the Act in the assessment order passed Under Section 143(3) r.w.s Section 147 of the Act and that deduction claimed by the appellant Under Section 54F of the Act was by inadvertent.

274 r.w.s 271(1)(c) of the Act. 7. Thereafter, the AO vide his order passed under section 271(1)(c) of the Act, dated 28/09/2022 imposed the penalty for concealment of income of Rs.5,03,585/- upon the assessee, i.e., with respect to the wrong claim of deduction under section 54F of the Act of Rs.16,29,727/- pertaining

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

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

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

section 274 r.w.s 270A of the Act.” 3. The brief facts of the case are that assessee is a company engaged in the business of Providing Information Technology (IT) and IT Enabled Services (ITES). The assessee company electronically filed its original return of income for A.Y.2018-19 declaring total income of Rs.822,84,01,030/- on 28.09.2018. The return of income

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

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

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

Transfer Pricing Officer (TPO) and the Honourable Dispute Resolution Panel (DRP) 1. Erred in not issuing Draft Assessment order as per procedure laid down u/s. 143(3) r.w.s 153A & 144C(1) of the Act by issuing the notice of demand u/s. 156 of the Act & penalty notices u/s. 271(1)(c) and 271AAB along with Draft assessment order dated