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

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

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

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

MBS JEWELLER PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3, HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

price. Share purchase agreements with the share holder of Mis. Gold Stone Technologies Private Limited were also seized during the search. Transfer of land to assessee group is also evident from various sale deeds. :- 15 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 11. It is submitted that it is evident from the statement of Shri Sukesh

MBS IMPES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

price. Share purchase agreements with the share holder of Mis. Gold Stone Technologies Private Limited were also seized during the search. Transfer of land to assessee group is also evident from various sale deeds. :- 15 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 11. It is submitted that it is evident from the statement of Shri Sukesh

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

2) The aggregate amount of the deductions43 under this Chapter shall not, in any case, exceed the gross total income of the assessee. 44[(3) Where, in computing the total income of an association of persons or a body of individuals, any deduction is admissible under section 80G or section 80GGA 45[or section 80GGC] or section 80HH or section

VITP PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

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

6 of 10 ITA Nos. 67 & 76/Hyd/2018 1st day of June, 2010, any property, being shares of a company not being a company in which the public are substantially interested" The words "firm or a company" "any property, being shares of a company" are important here. In this regard, we may refer to the Memorandum explaining the insertion of Provisions

VITP PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

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

6 of 10 ITA Nos. 67 & 76/Hyd/2018 1st day of June, 2010, any property, being shares of a company not being a company in which the public are substantially interested" The words "firm or a company" "any property, being shares of a company" are important here. In this regard, we may refer to the Memorandum explaining the insertion of Provisions

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

COMM VAULT SYSTEMS (INDIA) PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYD, HYDERABAD

In the result, assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahm/S. Comm Vault Systems Vs Dy. Commissioner Of Income (India) Private Limited Tax, Circle 1(2) Hyderabad Hyderabad Pan: Aaccc 3708 L (Appellant) (Respondent)

2) Not allowing the directions provided by DRP to reject the company "Dynacons Technologies Ltd" for computing the Arm's Length Margin. 3) Disregarding the inter-company Transfer Pricing methodology for recovery of losses incurred by Comm Vault India in the initial years of distribution. 4) Selection of most appropriate method Rejection of RPM and selection of TNMM

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