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

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

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

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

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

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

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

pricing adjustment.\n4.\nThereafter, the Ld. PCIT invoked provisions of section 263 of\nthe Act and issued notice to the assessee on 08.03.2024. The Ld.\nPCIT recorded that the Ld. AO during scrutiny assessment failed to\nexamine two specific issues, which is covered under Explanation\n2(a) to section 263 of the Act, thereby rendering the order erroneous\nand prejudicial

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

In the result, the appeal of the assessee in ITA

Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)

pricing adjustment. 4. Thereafter, the Ld. PCIT invoked provisions of section 263 of the Act and issued notice to the assessee on 08.03.2024. The Ld. PCIT recorded that the Ld. AO during scrutiny assessment failed to examine two specific issues, which is covered under Explanation 2(a) to section 263 of the Act, thereby rendering the order erroneous and prejudicial

SYED GULAM MOHIUDDIN,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-1, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita No.136/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Syed Gulam Vs. Income Tax Officer Mohiuddin (International Taxation)-1 Hyderabad Hyderabad Pan:Decpm0365H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Assessment Order Dated 12.01.2023 Of The Learned Assessing Officer (International Taxation-1), Hyderabad, Relating To A.Y.2017-18. 2. The Grounds Raised By The Assessee Read As Under: “1. The Final Assessment Order Passed By The Income Tax Officer (Int Taxn)-1,Hyd (Herein After Referred To As 'Ao) Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant.

transferred amount towards sale consideration to M/s Skill Promoters Private Ltd through proper banking channels. 16. The Ld. A.O making a huge addition of Rs. 22,00,000/- without 16. having any documentary and corroborative evidence especially u/s 69 as unexplained investment which is baseless. 17. The Ld. A.O ought to have appreciated the fact that the assessee

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes on the above terms

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

section is very clear and the appellant has incurred the expenditure and the appellant has made the payment to the various parties and persons. The appellant has, to circumvent, not accounted for the same and has also not brought out any evidence from M/s.DLF that they have accounted for such transactions in their books as cash payments. The MoU cannot

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

274 r.w.s. 271D on the ground that the assessee has violated the provisions of section 269SS of the I.T. Act which attracts levy of penalty u/s 271D of the I.T. Act. Before the Hon'ble High Court, the assessee, through the writ petition challenged the penalty levied u/s 271D on the ground that no satisfaction was recorded by the Assessing