NUNHEMS INDIA PRIVATE LIMITED,R.R.DIST vs. JCIT, RANGE 16, HYDERABAD

In the result, the assessee’s appeal for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

transfer does not require any human intervention and charges received or paid on account of this is not fees for technical services as envisaged in Section 194J read with Section 9(1)(vii) read with Explanation-2 of the Act. In case before us, the assessee has paid roaming charges i.e. IUC charges to various operators

NUNHEMS INDIA PRIVATE LIMITED,,HYDERABAD vs. ASST.CIT,CIRCLE 16(1),,

In the result, the assessee’s appeal for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

transfer does not require any human intervention and charges received or paid on account of this is not fees for technical services as envisaged in Section 194J read with Section 9(1)(vii) read with Explanation-2 of the Act. In case before us, the assessee has paid roaming charges i.e. IUC charges to various operators

DY. COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), HYDERABAD vs. UNION BANK OF INDIA, HYDERABAD

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

price of such govt. securities is revenue in nature and is allowable. The ld DR relied upon the order of the AO while the ld AR supported the order of the CIT (A) and also placed reliance upon the orders of the Tribunal in earlier A.Ys as well as the decision of the Hon'ble Supreme Page

UNION BANK OF INDIA,HYDERABAD vs. DY. COMMISSISONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

price of such govt. securities is revenue in nature and is allowable. The ld DR relied upon the order of the AO while the ld AR supported the order of the CIT (A) and also placed reliance upon the orders of the Tribunal in earlier A.Ys as well as the decision of the Hon'ble Supreme Page

DCIT, CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LIMITED, KOTHAGUDEM

vii) Any other grounds that may be urged at the time of hearing.\nITA No.286/Hyd/2024 (A.Y 2020-21) - (Assessee)\n1. Your Appellant submits that the provision of section 40A(9) are not applicable to the\nfacts of the case, being reimbursement/grant of deficit in the actual expenditure\nincurred by schools run by Singareni Educational Society, which is welfare\nexpenditure

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. DCIT., CIRCLE-13(1), HYDERABAD

In the result, assessee's appeals for the A

vii)\nAny other grounds that may be urged at the time of hearing.\nITA No.286/Hyd/2024 (A.Y 2020-21) - (Assessee)\n1. Your Appellant submits that the provision of Section 40A(9) are not applicable to the\nfacts of the case, being reimbursement/grant of deficit in the actual expenditure\nincurred by schools run by Singareni Educational Society, which is welfare\nexpenditure

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 :

vii) deal with transfer of shares pursuant to scheme of amalgamation. The above are specific and are not explicitly covered by the definition of amalgamation as the section 2(lB). There is no mention of the provision 47(vi) and 47(vib) which is amalgamation and demerger as they include all capital assets including no doubt shares from the purview

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G.\Nand\Nshri Ravish Sood\Nआ.अपी.सं /Ita No.917/Hyd/2024\N(निर्धारण वर्ष/Assessment Year:2020-21)\Nshakti Hormann Private\Nlimited,\Nhyderabad.\Nvs. Dcit,\Ncircle-3(1),\Nhyderabad.\Npan: Aadcs4024Q\N(Appellant)\N(Respondent)\Nनिर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao,\Nca\Nराजस्व द्वारा / Revenue By: Ms. U. Mini Chandran,\Ncit-Dr\Nसुनवाई की तारीख /Date Of Hearing: 15/10/2025\Nघोषणा की तारीख / Date Of 19/12/2025\Npronouncement:\Nआदेश / Order\Nper. Ravish Sood, J.M:\Nthe Present Appeal Filed By The Assessee Company Is Directed\Nagainst The Final Assessment Order Passed By The Assessing Officer (For\Nshort, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The\Nincome Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The\N Assessment Year (Ay) 2020-21. The Assessee Company Has Assailed\Nthe Impugned Order Passed By The Cit(A) On The Following Grounds Of\Nappeal Before Us:\N1. On The Facts & In The Circumstances Of The Case, The Final Assessment\Norder Passed U/S 143(3) R.W.S.144C(13) Of The Act Dated 25.07.2024 By\Nthe Ao & Also The Order Passed U/S 92Ca (3) Dt 30.07.2023 By The Tpo\Nare Bad In The Eyes Of Law & Thus, Unsustainable To The Test Of Appeal.\N2.0 The Final Assessment Order Passed U/S 143(3) R.W.S.144C(13) R.W.S.144B\Nis Beyond The Time Limit Prescribed U/S 153 Of The Act.\N2.

vii) prior year adjustments. After necessary\nverifications, the AO accepted the assessee's explanation on the issues\nother than the TP adjustment that was suggested by the TPO.\n6. The AO thereafter issued a draft assessment order under section\n144C(1) of the Act, dated 26/09/2023, wherein, after incorporating the\nTP adjustments, he proposed to assess the income

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

vii. Robosoft Technologies Private Limited viii. Aptus Software Labs Private Limited ix. Ksolves India Limited x. Cybage Software Private Limited xi. Consilient Technologies Private Limited xii. Yanolja Cloud India Private Limited (formerly eZee Technosys Private Limited) (e) Exclusion of comparable companies: i. e-Zest Solutions Limited ii. Yudiz Solutions Limited iii. Rheal Software Private Limited (f) Not including companies identified

DR. REDDYS, LABORATORIES 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.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

Transfer Pricing Adjustment 2. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price ("ALP") in respect of international loans to overseas Associated Enterprises by:  Directing the Ld. A.O/TPO to adopt the LIBOR rate applicable for the year under consideration+200 basis points to arrive at ALP instead

DR. REDDYS, LABORATORIES 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.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

Transfer Pricing Adjustment 2. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price ("ALP") in respect of international loans to overseas Associated Enterprises by:  Directing the Ld. A.O/TPO to adopt the LIBOR rate applicable for the year under consideration+200 basis points to arrive at ALP instead

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (I) PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 36(1)(vii) of the Act, which specifically states that, any provision for bad and doubtful debts is not an allowable expenditure unless it qualifies under the specific conditions mentioned therein. The legislative intent behind this provision is to allow only actual write off not merely provisions for future contingency. We have also gone through the Rule 10TA

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 36(1)(vii) of the Act, which specifically states that, any provision for bad and doubtful debts is not an allowable expenditure unless it qualifies under the specific conditions mentioned therein. The legislative intent behind this provision is to allow only actual write off not merely provisions for future contingency. We have also gone through the Rule 10TA

DSM SHARED SERVICES INDIA PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 8(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1358/Hyd/2024 Assessment Year 2021-2022 Dsm Shared Services India Private Limited, The Dcit, Circle-8(1), Hyderabad – 500 081. Hyderabad – 500 081. Vs. Telangana. Telangana. Pan Aadcd8407C (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09.12.2025 घोषणा की तारीख/Pronouncement: 12.12.2025 आदेश/Order

1. On the facts and circumstances of the case and in law, the final assessment order dated October 23, 2024 ("Impugned Order) passed by the Assessment Unit, Income Tax Department ("Ld. AO), pursuant to the Directions dated September 18, 2024 ('DRP Directions) issued by the Hon'ble Dispute Resolution Panel, Bengaluru ("Hon’ble DRP), and under section 143(3) read

ASIAN THEATRES PRIVATE LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-13(1), HYDERABAD

In the result, assessee’s appeal is treated as partly

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2012-13

transferred to P&L account on 31.03.2011. The assessee neither claimed these amounts as bad debts nor entered into his books of accounts as bad debts. As the assessee did not declare these amounts as bad debts, the same cannot be written off as bad debts as per the provisions of Sec.36. • Further, Rule-9B is a specific section

AUROBINDO PHARMA LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

In the result, appeal of the assessee is allowed

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

transfer pricing exercise as per any of the methods prescribed in section 92C (1) to determine the ALP, is bad in law and has to be deleted. 5. Second line of argument advanced on behalf of the assessee is that the assessee provided loans to its Associated Enterprises (“AEs”) for interest by showing the same in the P&L Account

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

Bench: Us :

prices less than FMV to a firm or company. The intent of legislation is to tackle transfer of shares and not the cases of primary allotment of the share. c) The assessee entered into an understanding with Kineta Global Limited and their promoters on 18-02-2010 for investing Rs. 50 crores for acquiring not less than 51% of Kineta

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

Bench: Us:

1)(a) of the Act, dated 30.11.2021 at Rs. 6,55,06,350/-) made TP adjustment as directed by the DRP-1, Bengaluru of Rs. 10,58,23,162/-, and determined its income at Rs. 17,13,29,510/-. 8 HighRadius Technologies Private Limited 8. The assessee company aggrieved with the order passed by the AO under Section

GSS INFOTECH LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

9. This is the assessee’s appeal against the order of AO dated 30/10/2018 passed u/s 143(3) rws 92CA(3) and 144C(13) of the IT Act, 1961. In this appeal, the assessee has raised the following grounds of appeal: S.No. Grounds of Appeal 1. The ld. AO erred in not passing the Draft Assessment order