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

Bench: Us:

transferred would have been less than the market value. The TPO, was of the view that since the assessee company had artificially increased the price of overhead cost incurred by the chilling units to the level of the market price, i.e., the price charged by the third party vendors, thus, such artificially increased price is to be benchmarked having regard

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)

transfer pricing adjustment. Accordingly, the adjustment towards purchases was revised to Rs. 47,92,29,000/-, and the adjustment towards royalty was treated as NIL. In pursuance of the directions issued by the Hon’ble DRP under Section

BHARATHI CEMENT CORPORATION PRIVATE LIMITED,,HYDERABAD vs. DCIT CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Bharathi Cement Corporation Vs. Deputy Commissioner Of Private Limited, Income Tax, Hyderabad. Circle – 2(1), Hyderabad. Pan : Aadcr3079G. (Appellant) (Respondent) Assessee By: Shri S. Kalyanasundaram, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.02.2023 Date Of Pronouncement: 17.02.2023

section 80-IA of the Income Tax Act. 1961 ("Act") in respect of profits and gains made by its captive power plant. 3. For that, without prejudice to the above, the AO and the DRP have erred in law by applying a transfer price in respect of power generated by the captive power plant of the assessee to its cement

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.

transfer pricing and it is for this reason that specific\ntimelines have been drawn within the framework of section 144C\nto ensure prompt and expeditious finalisation of this special\nassessment. The purpose is to fast-track a special type of\nassessment. That cannot be considered to mean that overall time\nlimits prescribed have been given

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

Bench: Us.

Transfer Pricing Officer;] (b) "record" shall include and shall be deemed always to have included all records relating to any proceeding under this Act available at the time of examination by the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner; (c) where any order referred to in this sub-section and passed by the Assessing Officer 92

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

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

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

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

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)

Transfer Pricing Officer to determine the arm’s length price of international transactions undertaken by the assessee. During the TP proceedings, the TPO noticed that the assessee had reported various international transactions including provision of software development services, receipt of software development services, reimbursement of expenses, and other support services as reported in Form 3CEB filed along with the return

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

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)

transfer pricing and it is for this reason that specific timelines have been drawn within the framework of section 1440 to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given

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 :

price lower than the Fair Market Value (F.M.V) of the shares, does not attract provisions of the section 56(2)(viia) of the Act and Ld.ClT (Appeals) erred in holding that provisions of Section 56(2)(viia) are not applicable to the transactions defined u/s.47(vi), even though the proviso to section 56(2)(viia) does not specify the transactions

INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE2(1), HYDERABAD

In the result, appeal of the Assessee for the assessment year 2021-2022 is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.943 & 1359/Hyd/2024 Assessment Years 2020-2021 & 2021-2022 Indeed India Operations The Acit, Private Limited, Vs. Circle-2(1), Hyderabad – 500 081. Hyderabad. Telangana Pan Aadci5931J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Mahima Goud, Advocate राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

transfer pricing and it is for this reason that specific timelines have been drawn within the framework of section 1440 to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

transfer pricing and it is for this reason that specific timelines have been drawn within the framework of section 1440 to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given

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

transfer pricing and it is for this reason that specific timelines have been drawn within the framework of section 1440 to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given

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)

transfer pricing and it is for this reason that specific timelines have been drawn within the framework of section 1440 to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given

TMEIC INDUSTRIAL SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2(1), HYDERABAD

In the result, both the Writ Petitions are allowed by setting aside the impugned assessment orders dated

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.422/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2018-19) Tmeic Industrial Systems Vs. Dy. Cit India Private Limited Circle 2 ( 1 ) Hyderabad Hyderabad Pan:Aadct5493J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Cas, Kranthi Palivela & Mrudulatha Devdas राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 17/12/2024 घोषणा की तारीख/Pronouncement: 24/02/2025 आदेश/Order

transfer pricing adjustment in the nature of interest on receivables amounting to INR 3,41,506/- b) Not appreciating that the instant transaction is not covered in the definition of international transaction as defined u/s 92B of the Act in the facts and circumstances of the case: c) Delinking the inter-company receivables arising from the main international transactions

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 and it is for this reason that specific timelines have been drawn within the framework of section 1440 to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given

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 and it is for this reason that specific timelines have been drawn within the framework of section 1440 to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given

WESTERN UP TOLLWAY LIMITED,NEW DELHI vs. DCIT CIRCLE -8(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

transfer pricing and it is for this reason that specific timelines have been drawn within the framework of section 144C to ensure prompt and expeditious finalisation of this special assessment. The purpose is to fast-track a special type of assessment. That cannot be considered to mean that overall time limits prescribed have been given