EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

Transfer Pricing Officer, as the case may be], wholly or partly, otherwise than by making a fresh assessment or reassessment [or fresh order under section 92CA, as the case may be], such effect shall be given within a 21 ITA.Nos.83

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

Transfer Pricing Officer, as the case may be], wholly or partly, otherwise than by making a fresh assessment or reassessment [or fresh order under section 92CA, as the case may be], such effect shall be given within a 21 ITA.Nos.83

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

prices much below their fair market value, it is proposed to amend section 56 to also include within its ambit transactions undertaken in shares of a company (not being a company in which public are substantially interested) either for inadequate consideration or without consideration where the recipient is a firm or a company (not being a company in which public

SIGNODE INDIA LIMITED,HYDERABAD vs. ACIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 92CA(1) of Income-tax Act, 1961, with the prior approval of the Pr. Commissioner of Income Tax-3, Hyderabad, for determination of arm's length price in respect of the Specified domestic/ International transactions reported by the assessee company for the financial year relevant to the assessment year 2016-2017. The TPO had issued notices u/sec.92CA

SIGNODE INDIA LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 92CA(1) of Income-tax Act, 1961, with the prior approval of the Pr. Commissioner of Income Tax-3, Hyderabad, for determination of arm's length price in respect of the Specified domestic/ International transactions reported by the assessee company for the financial year relevant to the assessment year 2016-2017. The TPO had issued notices u/sec.92CA

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

Bench: Us:

Section 143(3) r.w.s 144C(13) r.w.s 144B of the Act, dated 25.02.2024, has carried the matter in appeal before us. 9. We have heard the Ld. Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them

VENKATA KRISHNA TATINENI,SECUNDERBAD vs. ASST COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

83[Explanation 3.—For the purposes of this section, "Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation

MYLAN LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER INCOME TAX , CIRCLE-5 (1) , HYDERABAD

In the result, the ground no

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

83(SC), he also submitted that, if two views are possible, and the AO has adopted one of those views, the order of assessment cannot be prejudicial to the interests of the Revenue. The Ld. AR also submitted that even if there are some lac of enquiry on the part of the Ld. in pursuance to the provisions covered under

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

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

Section 144C(13) read with\nsection 144B of the Income Tax Act, 1961 ('the Act') by the Deputy Commissioner of Income Tax,\nCircle 2(1), Hyderabad ('Ld. AO') in pursuance of the directions issued by the Hon'ble Dispute\nResolution Panel - I, Bengaluru ('Hon'ble DRP') on the following grounds:\nOn the facts and circumstances of the case and contrary

SAXON GLOBAL INDIA PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

83,955/- as against income of Rs. 35,20,540/- declared by the appellant. 3. The addition of Rs.1,84,63,415/- being adjustment under section 92CA of the Income Tax Act, 1961 (the Act) made by the assessing officer is bad in law and thus the addition made needs to be deleted on the facts and circumstances

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

In the result, the appeals filed by the assessee is partly allowed\nfor statistical purposes

section 37(1)\nof the Act and re-compute the total income for the subject AY 2015-16.\nTATA Exlsi Limited ('TATA Exlsi') should be excluded from list of comparables\n2.1 That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in\nconfirming the acceptance of Tata Exlsi Ltd as comparable company.\n2.2 That

ZUARI CEMENT LIMITED,KADAPA vs. DCIT CIRCLE -1, NELLORE

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Transfer Pricing Officer ("TPO") and DRP erred on the facts and in law, in rejecting the economic analysis in the TP documentation filed by the Appellant in terms of the Section 92D of the Act read with Rule 10D of the Income Tax Rules, 1962 ("the Rules") and proceeded to make the TP addition based on re-determination

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

83,31,809/-) 3 M/s. Callidus Cloud (India) Private Limited 3.1. On the facts and in the circumstances of the case and in law, the Hon'ble DRP / the Assessment Unit / learned TPO erred in making an upward adjustment of ₹3,31,04,770/- to the transfer price of the Appellant’s international transactions in respect of SWD services provided

OPEN TEXT TECHNOLOGIES INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

83,190/-. The case was selected for scrutiny through CASS and since the\nassessee has entered into international transactions during the previous year relevant\nto the year under consideration. Therefore, the case was referred to the TPO for\ndetermination of the Arm's Length price (ALP). The profile of the assessee as taken\nfrom the transfer pricing study document

CORTEVA AGRISCIENCE SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

In the result, the Ground No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Transfer Pricing Officer (“Ld. TPO”) and approved by the Ld. CIT(A) are functionally not comparable with the assessee, therefore, they are required to be excluded. In this regard, the Ld. AR had filed a written submission in support of his contention, which is to the following effect : “Exclusion of comparable companies chosen by TPO - Ground no. 9 In this

SSNC FINTECH SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

Transfer Pricing Officer [in short “TPO"] to\ndetermine the ALP of the international transactions of the\nassessee with it's AEs. During the course of TP proceedings,\nthe TPO after considering the relevant TP analysis\ndocuments submitted by the appellant-company, has\nrejected the TP documentation and has conducted a fresh\nTP study by applying certain filters

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

Accordingly treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं / Ita-Tp No. 193/Hyd/2023 (निर्धारण वर्ष / Assessment Year: 2018-19) Infor (India) Private Limited, Vs. The Deputy Commissioner Hyderabad Of Income Tax, [Pan No. Aaacb6197Q] Circle-2(1), Hyderabad अपीलार्थीर्थी / Appellant प्रत्‍यर्थी / Respondent

section 260 and 144B of the Act. Hence the assessee is in appeal before us challenging the final assessment orders pursuant to the directions made by the Learned DRP. 5. Grounds No. 1 ,2 and 16 to 18 of this appeal are general in nature. Grounds No. 3 to 8 relate to the Transfer Pricing adjustment on account of provision

YERRAGUDI VENKATA SIVA REDDY,ANANTAPUR vs. ACIT., CIRCLE-1, KURNOOL

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1294/Hyd/2025 Assessment Year 2017-2018 Yerragudi Venkata Siva Reddy, Ananthapur The Acit, Vs. Pin – 515 001. Circle-1, Pan Aampy0365L Kurnool. Andhra Pradesh (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: -None- राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 17.02.2026 घोषणा की तारीख/Pronouncement: 20.02.2026 आदेश/Order

Section 48.  Pass such other order(s) as may be deemed fit in the interest of justice.” 6 ITA.No.1294/Hyd./2025 4. The solitary issue raised by the assessee in this appeal is regarding the disallowance of claim of Rs.11,24,472/- towards the indexed cost of demolition of the structure on the land against the capital gain arising from