GVR POWER & INFRASTRUCTURE LIMITED,KADIYAM vs. ACIT, CIRCLE - 2(1), RAJAHMUNDRY

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TP) study and adopted the Comparable Uncontrolled Price (“CUP”) method as most appropriate method for bench marking the transaction of corporate guarantee. The assessee in it’s Transfer pricing documentation has conducted the search using the ‘Bloomberg’ database to identify the market yield on debt securities with credit ratings. The assessee has used the US Industrial Bond Yield Curve

THE DY. CIT,, VISAKHAPATNAM vs. M/S. SNF (INDIA) LIMITED,, VISAKHAPATNAM

In the result, appeals filed by the Revenue and the Cross objections filed by the assessee are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

disallowance of Royalty.‖ 3. During the appeal hearing, ld.DR submitted that ground Nos. 1 to 3 are related to the benefit test made by the Transfer Pricing Officer (TPO) for allowing royalty payment. Ground Nos.4 to 7 are related to determination of arm’s length price (ALP) in respect of payment of royalty to the Associated Enterprises (AEs). 4. Brief

THE DY. CIT,, VISAKHAPATNAM vs. M/S. SNF (INDIA) LIMITED,, VISAKHAPATNAM

In the result, appeals filed by the Revenue and the Cross objections filed by the assessee are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

disallowance of Royalty.‖ 3. During the appeal hearing, ld.DR submitted that ground Nos. 1 to 3 are related to the benefit test made by the Transfer Pricing Officer (TPO) for allowing royalty payment. Ground Nos.4 to 7 are related to determination of arm’s length price (ALP) in respect of payment of royalty to the Associated Enterprises (AEs). 4. Brief

DEVI SEA FOODS LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE -3(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.156/Viz/2022 (निर्धारण वर्ा / Assessment Year : 2018-19) M/S Devi Sea Foods Limited Vs. Deputy Commissioner Of 50-1-51/1, A.S.R.Nagar Income Tax Seethammadhara Circle-3(I) Visakhapatnam Visakhapatnam [Pan : Aabcd0248B] अपीलधथी की ओर से/ Appellant By : Shri D.Anand, Ar प्रत्यधथी की ओर से / Respondent By : Shri M.N.Murthy Naik, Cit(Dr) सुिवधई की तधरीख / Date Of Hearing : 01.12.2022 घोर्णध की तधरीख/Date Of Pronouncement : 16.12.2022 O R D E R Per Shri S.Balakrishnan:

TP adjustment and assessed the total income at Rs.308,75,13,245/- by making the following disallowances : 1. Disallowance u/s 80G 1,69,500 2. Disallowance u/s 92 CA(3) 7,69,33,812 3. Disallowance u/s 14A r.w.Rule 8D 12,27,953 Total 7,83,31,265 4. Aggrieved by the order of the Ld.AO, the assessee filed objections

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

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

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.340/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) & S.A. No. 15/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2020-21) Teejay India Private Limited, Vs. Deputy Commissioner Of Plot No. 15, Brandix, Apsez, Income Tax, Pudimadaka Road, Atchutapuram Circle-5(1), Mandal, Visakhapatnam-530011. Visakhapatnam. Pan: Aaaco9452H (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TP-3, Hyderabad (Ld TPO) passed U/s. 92CA of the Act is contrary to law and thus liable to be quashed. 5 Teejay India Private Limited vs. DCIT 3. That on facts and in the circumstances of the case, the Ld. AO/TPO and the Ld. DRP erred in making an upward adjustment to the transfer price of the appellant

DEVI SEA FOODS LIMITED,VISAKHAPATNAM vs. DCIT, CIRCLE-3(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.75/Viz/2022 ("नधा"रणवष"/ Assessment Year: 2017-18) M/S. Devi Sea Foods Limited, Vs. Deputy Commissioner Of Visakhapatnam. Income Tax, Pan: Aabcd 0248 B Circle-3(1), Visakhapatnam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri D. Anand, Advocate ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

TP adjustment to the total income to the tune of Rs. 50,57,43,750/- and further made a disallowance u/s. 14A for Rs. 13,20,907/- in his draft assessment order U/s. 144C of the Act. Aggrieved by the order of the Ld. AO, the assessee filed objections before the Ld. DRP-1, Bengaluru and challenged the upward adjustments

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

method but while doing so, started cherry-picking the sizes favourable to them with the sole intention of making the TP adjustment which is unfair and unjust. Later on, when the matter reached to the Ld. CIT(A), the assessee relied on various case laws as well as the decision of the Ld. CIT(A) in the assessee

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

method but while doing so, started cherry-picking the sizes favourable to them with the sole intention of making the TP adjustment which is unfair and unjust. Later on, when the matter reached to the Ld. CIT(A), the assessee relied on various case laws as well as the decision of the Ld. CIT(A) in the assessee

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, DUGGIRALA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

method but while doing so, started cherry-picking the sizes favourable to them with the sole intention of making the TP adjustment which is unfair and unjust. Later on, when the matter reached to the Ld. CIT(A), the assessee relied on various case laws as well as the decision of the Ld. CIT(A) in the assessee

3F INDUSTRIES LIMITED,TADEPALLIGUDEM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

TP Adjustment of Rs. 14,05,566/- pertaining to interest on working capital and term loans of Rs. 62, 64,747/- in respect of specific domestic transactions. Considering the TPO’s order, the Ld. AO completed the scrutiny proceedings and passed a draft order U/s. 143(3) r.w.s 144C(3), dated 24/11/2016. The Ld. AO later finalized the draft assessment

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

TP-3, Hyderabad (for short “TPO”) for determining the Arm’s Length Price (for short, “ALP”) in respect of all the transactions reported by the assessee-company in its Transfer Pricing Study Report (for short, “TPSR”) in its Form 3CEB. 4. The TPO vide his order passed under section 92CA(3) of the Act, dated 31.10.2023, analysed the International Transactions

VIDYAVATHI MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

disallowing the cost of indexation and cost of improvement and after considering the investment U/s. 54EC of the Act, computed the taxable income under capital gains at Rs. 5,435/-. The Ld. AO thus completed the assessment U/s. 143(3) r.w.s 147 of the Act on 19/03/2022 assessing the total income at Rs. 7,80,035/-. 3. Thereafter, by virtue

SIVAKAMA SUNDAR MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

disallowing the cost of indexation and cost of improvement and after considering the investment U/s. 54EC of the Act, computed the taxable income under capital gains at Rs. 5,435/-. The Ld. AO thus completed the assessment U/s. 143(3) r.w.s 147 of the Act on 19/03/2022 assessing the total income at Rs. 7,80,035/-. 3. Thereafter, by virtue

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, DC/AC 4(1), VISAKHAPATNAM

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

disallowance of technical support service fee paid. The Ld. AR argued that the assessee has submitted the technical support services agreement before the Ld. TPO. The Ld. AR 12 vehemently argued that the technical support services fee was incurred wholly and exclusively for the purpose of business operations. The Ld. AR also further submitted that technical services fee from