THERMODYNE DYNAMICS PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD -17(3), HYDERABAD

Bench: Us :

6. Whether the learned Authorities below are correct in computed fair market value of each of Rs. 15.82/- under section 11UA r.w.s 56[2] [viia] of the Act, under the facts and circumstances of the case. 7. The Appellant denies the liability to pay interest under section 234B & 234C of the Act, in view of the fact that there

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA; (v) any transaction, referred to in any other section under Chapter VI- A or section 10AA, to which provisions of sub-section

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Transfer Pricing Officer (TPO) in respect of specified domestic transactions reported by the assessee company. The TPO, after examining the submissions and documentation furnished by the assessee company, passed an order under section 92CA(3) of the Act, determining the arm's length price (ALP) of the specified domestic transactions and did not propose any adjustment. 4. Thereafter

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

Transfer Pricing Officer (TPO) were to be quashed. We further find that the Hon’ble High Court of Punjab & Haryana in the case of CIT vs. Nagendra Prasad (2013) 156 Taxmann.com 19 (Punjab & Haryana) had observed that where the notice was issued by AO under section 148 of the Act requiring the assessee to file a return within 30 days

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Transfer Pricing Officer\n(TPO) in respect of specified domestic transactions reported by the\nassessee company. The TPO, after examining the submissions and\ndocumentation furnished by the assessee company, passed an order\nunder section 92CA(3) of the Act, determining the arm's length price\n(ALP) of the specified domestic transactions and did not propose any\nadjustment.\n4.\nThereafter

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

2) The aggregate amount of the deductions43 under this Chapter shall not, in any\ncase, exceed the gross total income of the assessee.\n44[(3) Where, in computing the total income of an association of persons or a body\nof individuals, any deduction is admissible under section 80G or section 80GGA\n45[or section 80GGC] or section 80HH or section

NATEMS SOLAR POWER PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD 16(1), HYDERABAD

Bench: Us:

6. Accordingly, the TPO directed the AO to enhance the total income of the assessee company by Rs.25,44,958/- u/s 92CA of the Act. 7. The AO, on receipt of the order passed by the TPO u/s 92CA(3) of the Act, dated 30.12.2022, called upon the assessee company to explain that as to why a transfer pricing adjustment

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

Section 143(2) of the Act. 5. During the course of the assessment proceedings, the A.O. made a reference u/s 92CA of the Act to the DCIT, T.P.-1, Hyderabad, for determination of the “Arm’s Length Price” (for short, “ALP”) of the specified domestic transactions reported by the assessee company for the subject year. 6. The Transfer

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

transfer pricing adjustment qua the provision of IT services. 3. When the assessee filed objections before the learned DRP, learned DRP, while confirming the disallowance of deduction under section 80G of the Act, issued certain directions. Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

transfer pricing adjustment qua the provision of IT services. 3. When the assessee filed objections before the learned DRP, learned DRP, while confirming the disallowance of deduction under section 80G of the Act, issued certain directions. Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1,, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

price of the international taxation. We find the provisions of section 153(2) read as under: “ 153. Time limit for completion of assessment, reassessment and re-computation. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

BHARATHI CEMENT CORPORATION PRIVATE LIMITED,,HYDERABAD vs. DCIT CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Bharathi Cement Corporation Vs. Deputy Commissioner Of Private Limited, Income Tax, Hyderabad. Circle – 2(1), Hyderabad. Pan : Aadcr3079G. (Appellant) (Respondent) Assessee By: Shri S. Kalyanasundaram, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.02.2023 Date Of Pronouncement: 17.02.2023

section 80-IA of the Income Tax Act. 1961 ("Act") in respect of profits and gains made by its captive power plant. 3. For that, without prejudice to the above, the AO and the DRP have erred in law by applying a transfer price in respect of power generated by the captive power plant of the assessee to its cement

INTERWRAP CORP PRIVATE LIMITED (SUCCESSOR OF OWENS CORNING INDUSTRIES (INDIA) PRIVATE LIMITED),MUMBAI vs. DCIT., CIRCLE -5(1), HYDERABAD

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)

2) of the Income-tax Act, 1961 was issued on 23.09.2019. Further, notices under Section 142(1) along with detailed questionnaire were issued on 21.12.2020 and 13.08.2021, to which the assessee submitted replies on 05.01.2021 and 17.08.2021. 6 Interwrap Corp Private Ltd 5. During the course of assessment proceedings, the A.O. made a reference to the Transfer Pricing