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

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD 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 G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

80G towards CSR expenditure. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Ms. Tanmayee Rajkumar, Advocate, referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.06.2024, submitted that, the assessment order passed

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

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)

80G towards CSR expenditure, disallowance under Section 40(a)(ia), and addition towards Form 26AS mismatch. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Shri Sriram Seshadri, C.A., referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s

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.

5. The Ld. DRP/TPO erred in not appreciating that the amendment to section 92B would not apply to the year under consideration as it was inserted on a later date. The amendment has to be interpreted as prospective in nature. 6. The Ld. DRP/TPO erred in not appreciating the fact that Rain CII Carbon, LLC (RCC') had also provided guarantee

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

80G of the Act amounting to INR 10,43,860 and further erred in not granting an opportunity of being heard to the Appellant, to present its case on merits, before denial of such deduction. 22. On the facts and circumstance of the case and in law, the Ld. AO erred by granting credit of tax deducted at source

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

80G of the Act amounting to INR 10,43,860 and further erred in not granting an opportunity of being heard to the Appellant, to present its case on merits, before denial of such deduction. 22. On the facts and circumstance of the case and in law, the Ld. AO erred by granting credit of tax deducted at source

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NAVA BHARAT VENTURES LIMITED, HYDERABAD

Appeal is partly allowed in above terms

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

80G deduction of Rs.13.10 lakhs along with Section 80-IA deduction of Rs.121,32,88,080/- followed by Section 115JB book profits at Rs.296,63,14,260/-. 5. The Assessing Officer noticed during the course of scrutiny that the assessee had entered into international transactions with its overseas Associated Enterprise ‘AE’ in various segments. He thus made Section 92CA reference

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

III to the Companies Act, 2013.” 9.2 Thus, on perusal of above we find that there is no dispute on the fact that the assessee is engaged in rendering multiple services, including both digital marketing services and SDS. ITA No.1747/Hyd/2019 17 9.3 We have also gone through Note No. 16 relating to “Revenue from Operations” in the financial statements placed

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

Appeal is partly allowed in above terms

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

transfer pricing analysis/ study prepared by the Appellant and conducting fresh benchmarking, without appreciating that none of the conditions mentioned in clauses (a) to (d) of Section 92C(3) of the Act were satisfied. SOFTWARE DEVELOPMENT SERVICES (SDS) SEGMENT 3. On the facts and in the circumstances of the case and in law, the Ld.TPO erred

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

80G or section 80GGA\n45[or section 80GGC] or section 80HH or section 80HHA or section 80HHB or\nsection 80HHC or section 80HHD or section 80-1 or section 80-IA 46[or section\n80-IB] 47[or section 80-IC] 49[or section 80-ID or section 80-IE] or section 80J or\nsection 80JJ50, no deduction under

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

In the result, appeal of the Assessee is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

transfer pricing provisions and the Hon'ble DRP has further erred in upholding the action of Ld. TPO/AO. 1.4 That on the facts and in the circumstances of the case and in law, the Ld. TPO/Ld. AO has erred in disregarding the judicial precedent of the Hon'ble Income-Tax Appellate Tribunal (ITAT), Hyderabad in the case of Adama India

NATCO PHARMA LIMITED,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

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

Bench: Shri K. Narasimha Chary & Shri G. Manjunatha

iii) whether separate adjustment for receivables is required once working capital adjustment has been allowed, iv) whether adjustment on account of receivables is not warranted unless profitability of comparable companies is higher after adjustments. The TPO after relying on 10 ITA.No.853/Hyd./2024 decisions of (1) Ameriprise India Pvt Ltd vs., ACIT 2015-TII- 347-ITAT-Delhi-TP (2) Techbooks

PLANET ONLINE PVT.LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-16(2), HYDERABAD, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmana.Y.2011-12

transfer pricing issues to the TPO which is in violation of principles of natural justice. 1.c The AO ought to have independently applied his mind to the order of the TPO with due cognizance to the appellant's various rebuttals before accepting mechanically, the conclusions stated in the TPO's order. 1.d The TPO erred in making