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

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 Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues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 Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues

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

iv) PCIT vis S. T. Ericsson India Pvt. Ltd. ITA no.821/2017, dated 31.01.2018; v) S. T. Ericsson India Pvt. Ltd. vis ACIT, ITA no.1672/Del./ 2014; vi) Dialogic Networks India Pvt. Ltd. vis ACIT, ITA no. 7280/Mum/ 2012, dated 27.07.2018; and vii) Accenture Services Pvt. Ltd. vis ACIT, [2018) 96 taxmann.com 37. The learned Departmental Representative submitted, before the Transfer Pricing

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

iv) PCIT vis S. T. Ericsson India Pvt. Ltd. ITA no.821/2017, dated 31.01.2018; v) S. T. Ericsson India Pvt. Ltd. vis ACIT, ITA no.1672/Del./ 2014; vi) Dialogic Networks India Pvt. Ltd. vis ACIT, ITA no. 7280/Mum/ 2012, dated 27.07.2018; and vii) Accenture Services Pvt. Ltd. vis ACIT, [2018) 96 taxmann.com 37. The learned Departmental Representative submitted, before the Transfer Pricing

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

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

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

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.

IV, M/s: Rain CII Holdings Inc, a wholly owned subsidiary company of the assessee, acquired shares in M/s. Juniper Investment LLC, which in turn owned all the outstanding shares of CII Carbon LLC from M/s. Cadogan Holdings B.V. For this purpose, the assessee company borrowed USD 120.67 Million from Banks, and incurred finance charges' amounting to Rs.17

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

price is determined on the basis of range concept i.e., 35th percentile and 65th percentile. The TPO 13 ITA.No.853/Hyd./2024 also noted that the instant issue is squarely covered by the decision of Coordinate Bench of Hyderabad Tribunal in the case of M/s.Tecumseh Products India Pvt Ltd, Hyderabad in ITA No.2228/Hyd/2011 wherein Hon'ble ITAT categorically held that

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

80G of the Act in respect of eligible donations/ payments made by Appellant for the year under consideration based on the assessed Gross Total Income. 6.1. Without prejudice to Grounds 4 & 5 above, that on the facts and in the circumstances of the case and in law, Hon'ble DRP erred in holding that the donations/payments made by Appellant were