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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Section 928 of Income-tax Act, 1961 ('the Act'). 7.2. in law and facts and circumstances of the case, the Ld. DRP and Ld. TPO/AO have erred in making a transfer pricing

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Section 928 of Income-tax Act, 1961 ('the Act'). 7.2. in law and facts and circumstances of the case, the Ld. DRP and Ld. TPO/AO have erred in making a transfer pricing

VERMEIREN INDIA REHAB PRIVATE LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Manjunatha G & Shri Ravish Sood

Section 928 of Income-tax Act, 1961 ('the Act'). 5 ITA.No.1315 /Hyd./2024 7.2. in law and facts and circumstances of the case, the Ld. DRP and Ld. TPO/AO have erred in making a transfer pricing

APACHE FOOTWEAR INDIA PRIVATE LIMITED,NELLORE vs. ACIT, CIRCLE-1(1), TIRUPATI

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

Transfer Pricing Officer) by the Assessing Officer, on 06.02.2021 after obtaining the approval of the Pr. Commissioner of Income-Tax. Accordingly, the TPO passed an order u/s 92CA(3) of the Income-tax Act. 1961 determining no upward adjustment u/s.92CA of the Act. Further, the TPO passed an order dt.06.08.2021 u/s 154 of the Act for AY 2018-19 determining

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

928: "Capital financing, including any type of long-tern or short-term borrowing, lending or guarantee, purchase or sale of marketable securities or any type of advance, payments or deferred payment or receivable or any other debt arising during the course of business". Section 92F(v): "Transaction" includes an arrangement, understanding or action in concer4- A. whether or not such

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

928: "Capital financing, including any type of long-tern or short-term borrowing, lending or guarantee, purchase or sale of marketable securities or any type of advance, payments or deferred payment or receivable or any other debt arising during the course of business". Section 92F(v): "Transaction" includes an arrangement, understanding or action in concer4- A. whether or not such

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD, HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

928: "Capital financing, including any type of long-tern or short-term borrowing, lending or guarantee, purchase or sale of marketable securities or any type of advance, payments or deferred payment or receivable or any other debt arising during the course of business". Section 92F(v): "Transaction" includes an arrangement, understanding or action in concer4- A. whether or not such

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

928: "Capital financing, including any type of long-tern or short-term borrowing, lending or guarantee, purchase or sale of marketable securities or any type of advance, payments or deferred payment or receivable or any other debt arising during the course of business". Section 92F(v): "Transaction" includes an arrangement, understanding or action in concer4- A. whether or not such

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

Section 92CA of the IT Act, directions given by DRP u/s 144C(5) of the Act and “Give Effect to Directions u/s 144C order of the TPO dt.19.03.2021, the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act was passed and the total income of the assessee was assessed at Rs.49,99,97,796/-. Thereafter

IVY COMPTECH PRIVATE LIMITED,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuay : 2013-14 Ivy Comptech Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1) Hyderabad. Pan – Aaaci 8884K (Appellant) (Respondent) Assessee By: Shri Prashant Meharchandani Revenue By: Shri R. Dipak Date Of Hearing: 27/04/2021 Date Of Pronouncement: 20/07/2021

Transfer Pricing adjustment. 4. Levying of interest u/ s 234C of the Act. 5. Initiating penalty proceedings u/ s 271AA and 271 BA of the Act. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete or modify all or any of the above grounds

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

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 92CA of the Act. Thereafter, the case was referred to the Transfer Pricing Officer (TPO) in order to get arm’s length price of those transactions determined by the TPO. The TPO vide order u/s 92CA(3) of the Act dt.31.07.2021 proposed an amount of Rs.38,74,591/- in respect of interest on delayed receivables as the transfer pricing

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED., HYD,HYDERABAD vs. DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 Hyundai Motor India Engg. Pvt. Vs. Dy. Commissioner Of Income- Ltd., Hyderabad Tax, Circle – 2(2), Hyderabad.

928 Company Reimbursement of 3,63,21,335 expenses Receivables 6,34,42,881 Kia Motor Provision of ITES 23,26,70,265 Corporation Receivables 4,32,08,022 2.4 Examination of TP study conducted by assessee: The assessee has carried out the economic analysis and has summarized it as under: Nature of Amount MAM PLI Margin of Margin

APPLABS TECHNOLOGIES PVT LTD (NOW MERGED WITH COMPUTER SCIENCE CORPORATION PVT LTD ),,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1, HYDERABAD

In the result, the appeal of the assessee for the A

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

transfer price officer (“Ld. TPO”). However, the assessee filed rectification application before the Ld. TPO on 01/03/2016 and consequently the Ld. TPO revised his order on 27/01/2017. On the basis of said revised order of Ld. TPO, Ld. AO passed the revised order on 13/02/2017, determining the total income under the normal provision

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD vs. APPLABS TECHNOLOGIES PVT. LTD. (NOW MERGED WITH M/S COMPUTER SCIENCE INDIA PVT. LTD.), HYDERABAD

In the result, the appeal of the assessee for the A

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

transfer price officer (“Ld. TPO”). However, the assessee filed rectification application before the Ld. TPO on 01/03/2016 and consequently the Ld. TPO revised his order on 27/01/2017. On the basis of said revised order of Ld. TPO, Ld. AO passed the revised order on 13/02/2017, determining the total income under the normal provision

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED (PREVIOUSLY KNOWN AS APPLABS TECHNOLOGIES PRIVATE LIMITED),HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee for the A

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

transfer price officer (“Ld. TPO”). However, the assessee filed rectification application before the Ld. TPO on 01/03/2016 and consequently the Ld. TPO revised his order on 27/01/2017. On the basis of said revised order of Ld. TPO, Ld. AO passed the revised order on 13/02/2017, determining the total income under the normal provision

MYLAN LABORATORIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

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

928 Mn. 10.1 In terms of the amalgamation scheme, the excess of investment made over the aggregate value of the net assets acquired and liabilities assumed, the intangibles including goodwill were depreciated @ 25% on WDV from the Financials submitted. The AO observed that the price of the intangible asset was in the form of goodwill has been introduced

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. MYLAN LABORATORIES LIMITED , HYDERABAD

In the result, appeal of the assessee is partly allowed

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

928 Mn. 10.1 In terms of the amalgamation scheme, the excess of investment made over the aggregate value of the net assets acquired and liabilities assumed, the intangibles including goodwill were depreciated @ 25% on WDV from the Financials submitted. The AO observed that the price of the intangible asset was in the form of goodwill has been introduced

INCOME TAX OFFICER, WARD-4(5), HYDERABAD vs. SHRILEKHA FINANCIAL SERVICES (PRESENTLY KNOWN AS M/S SHRILEKHA BUSINESS CONSULTANCY), HYDERABAD

In the result, both the appeals of the revenue are dismissed

Bench: Shri C.N.Prasad, Jm & Shri M.Balaganesh, Am & Income Tax Officer, Vs. M/S. Shrilekha Business Consultancy Ward – 4(5) Pvt. Ltd., (Pan No.Aaycs0021L) Hyderabad (Formerly M/S. Shrilekha Financial Services Initially & Subsequently M/S. Shrilekha Business Consultancy, Both Are With Pan:Aacfs9088A 3-6-478, Iv Floor, Anand Estate, Liberty Road, Himayath Nagar Hyderabad Pan/Gir No. Aacfs9088A (Appellant) .. (Respondent)

section 14 of the Partnership Act. Thus it was deployed by Shrilekha for eventually getting adequate stake in SCL to enable PEL to have 20% interest in SCL while remaining as a partner in Shrilekha. 6.2. The ld. CIT(A) deleted the addition by meeting all the allegations levelled by the ld. AO in his assessment order, by considering