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

Bench: Us :

9. In the view of the above and other grounds that may be urged at the time of the hearing of the appeal, the Appellant prays that the appeal may be allowed in the interest of justice and equity.” 2. Succinctly stated, the assessee company had filed its return of income for A.Y. 2013-14 on 29.09.2013, declaring an income

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

9. Per contra, the Ld. DR had submitted that section 92BA provides the definition of the Specified Domestic Transaction, which is to the following effect: “Meaning of specified domestic transaction. 92BA. For the purposes of this section and sections 92, 92C, 92D and 92E, "specified domestic transaction" in case of an assessee means any of the following transactions, not being

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Transfer Pricing Officer (TPO) in respect of specified domestic transactions reported by the assessee company. The TPO, after examining the submissions and documentation furnished by the assessee company, passed an order under section 92CA(3) of the Act, determining the arm's length price (ALP) of the specified domestic transactions and did not propose any adjustment. 4. Thereafter

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

9 Sanghi Textiles Privarte Limited vs. ITO submitted to demonstrate the nexus between deposits and business income. The appellant failed to substantiate the cash flow, provide bank statements, or reconcile deposits with disclosed income. In absence of any verifiable explanation, the AO was justified in invoking section 698. The Hon'ble Delhi High Court in CIT v. Lubtec India

NATEMS SOLAR POWER PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD 16(1), HYDERABAD

Bench: Us:

9. Without prejudice, the Ld. AO and the Ld. TPO, under the directions of the Hon’ble DRP, erred in adding the amount of transfer pricing adjustment to the total income of the Appellant 4 Natems Solar Power Private Limited without appreciating the fact that Assessee has not claimed a deduction of the interest towards purchase on supplier credit

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

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

transfer of substantial funds while retaining control over the funds, the provision\nof section 40A(9) of the Income Tax Act, 1961 are applicable, the addition may be\ndeleted.\n3. Your Appellant submits that it is an undisputed fact from the account of the society that\nthe funds paid are to mitigate the deficit of funds in running the Scholls

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

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

In the result, assessee's appeals for the A

transfer of substantial funds while retaining control over the funds, the provision\nof Section 40A(9) of the Income Tax Act, 1961 are applicable, the addition may be\ndeleted.\n3. Your Appellant submits that it is an undisputed fact from the account of the society that\nthe funds paid are to mitigate the deficit of funds in running the Scholls

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

2. On the facts and in the circumstances of the case and in law, the Ld. Panel erred in upholding the action of the Ld. Transfer Pricing Officer ('Ld. TPO')/Ld. AO in proposing an adjustment of INR 19,43,26,338 to the specified domestic transactions ('SDTs') pertaining to inter-unit transfer of milk. 3. On the facts

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)

9. Aggrieved by the draft assessment order, the assessee filed objections before the learned DRP on 26-04-2023 and challenged the addition made by the AO. DRP-1, Bangalore issued directions under Section 144C(5) of the Act, on 07-12-2023 and rejected the objections filed by the assessee and uphold the addition made by the Assessing Officer

MIR IBRAHIM ALI,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)

9. Aggrieved by the draft assessment order, the assessee filed objections before the learned DRP on 26-04-2023 and challenged the addition made by the AO. DRP-1, Bangalore issued directions under Section 144C(5) of the Act, on 07-12-2023 and rejected the objections filed by the assessee and uphold the addition made by the Assessing Officer

MIR IBRAHIM ALI,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)

9. Aggrieved by the draft assessment order, the assessee filed objections before the learned DRP on 26-04-2023 and challenged the addition made by the AO. DRP-1, Bangalore issued directions under Section 144C(5) of the Act, on 07-12-2023 and rejected the objections filed by the assessee and uphold the addition made by the Assessing Officer

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)

9. Aggrieved by the draft assessment order, the assessee filed objections before the learned DRP on 26-04-2023 and challenged the addition made by the AO. DRP-1, Bangalore issued directions under Section 144C(5) of the Act, on 07-12-2023 and rejected the objections filed by the assessee and uphold the addition made by the Assessing Officer

INTERWRAP CORP PRIVATE LIMITED (SUCCESSOR OF OWENS CORNING INDUSTRIES (INDIA) PRIVATE LIMITED),MUMBAI 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 VIJAY PAL RAO, HON'BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

section 1448 of the Income-tax Act pursuant to the directions dated 14 June 2022 by Dispute Resolution Panel, Bangalore (DRP) u/s 144C(5) of the Act, is bad in law and void ab initio so far as it is prejudicial to the Appellant. Transfer Pricing Adjustment 2. That on the facts and circumstances of the case

HIMASAGAR KRISHNA MUTHAPPAGARI,TIRUPATI vs. ITO., WARD-2(3), TIRUPATI

Bench: Us.

2" to Sec.263(1) of the Act, observed that the failure on the part of the AO to make any 8 Himsagar Krishna Vs. Pr. CIT, Tirupati examination/verification/enquiries, which were required to have been made qua the assessee's claim for exemption under Section 54F of the Act, had rendered his order as erroneous insofar as it was prejudicial