“draft assessment order”

Sri Rama Agri Genetics (India) Private Limited, Kurnool vs. DCIT., Circle-1, Kurnool

In the result, the appeal of the assessee is partly allowed

assessee has furnished bills of purchases and PAN details in a few cases, the same were furnished after the show-cause notice and draft assessment orders were issued. The A.O. further noted that, although the assessee was having the above details, but purposefully the assessee has not provided the details

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad and Before Shri Manjunatha G

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

perused the order of the Tribunal, in view of the undisputed facts before us about the manner in which the approval to the draft assessment order was granted under section 153D for the assessment proceedings, by a letter dated 30-12-2017 in 85 cases placed before the approving authority ... Navin Jain (supra) wherein a detailed discussion has been made with regard to the requirement of prior approval of superior authority on the draft assessment order under section 153D, before passing the assessment order by the Assessing Officer. It was noted that the word 'approval' though has not been defined

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

perused the order of the Tribunal, in view of the undisputed facts before us about the manner in which the approval to the draft assessment order was granted under section 153D for the assessment proceedings, by a letter dated 30-12-2017 in 85 cases placed before the approving authority ... Navin Jain (supra) wherein a detailed discussion has been made with regard to the requirement of prior approval of superior authority on the draft assessment order under section 153D, before passing the assessment order by the Assessing Officer. It was noted that the word 'approval' though has not been defined

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. DCIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

perused the order of the Tribunal, in view of the undisputed facts before us about the manner in which the approval to the draft assessment order was granted under section 153D for the assessment proceedings, by a letter dated 30-12-2017 in 85 cases placed before the approving authority ... Navin Jain (supra) wherein a detailed discussion has been made with regard to the requirement of prior approval of superior authority on the draft assessment order under section 153D, before passing the assessment order by the Assessing Officer. It was noted that the word 'approval' though has not been defined

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

perused the order of the Tribunal, in view of the undisputed facts before us about the manner in which the approval to the draft assessment order was granted under section 153D for the assessment proceedings, by a letter dated 30-12-2017 in 85 cases placed before the approving authority ... Navin Jain (supra) wherein a detailed discussion has been made with regard to the requirement of prior approval of superior authority on the draft assessment order under section 153D, before passing the assessment order by the Assessing Officer. It was noted that the word 'approval' though has not been defined

Sgd Pharma India Private Limited, Hyderabad vs. ITO Ward-3(1), Hyderabad

In the result, the appeal of the assessee in ITA

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita-Tp Nos.130 & 447/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S. Sgd Pharma India Vs. Dy.Cit/I.T.O Private Limited, Ward/Circle 3 (1) Mahabubnagar Hyderabad Pan:Aadcc7815K (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Aliasgar Rampurwala, Ca राज" व "ारा/Revenue By:: Smt. K. Haritha, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 21/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

respect of the international transaction relating to interest on External Commercial Borrowings (“ECB”). Based on the said order, the Ld. AO passed a draft assessment order dated 13.04.2021. 5. Aggrieved by the order of the Ld. AO, the assessee filed objections before the Ld. DRP. The Ld. DRP disposed

Sgd Pharma India Private Limited, Mahabubnagar vs. DCIT, Circle -3 (1), Hyderabad

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita-Tp Nos.130 & 447/Hyd/2022 (निर्धारण वर्ष/Assessment Years: 2017-18 & 2018-19) M/S. Sgd Pharma India Vs. Dy.Cit/I.T.O Private Limited, Mahabubnagar Pan:Aadcc7815K (Appellant) Ward/Circle 3 (1) Hyderabad (Respondent) निर्धारिती द्वारा / Assessee By: Shri Aliasgar Rampurwala, Ca राजस्व द्वारा / Revenue By:: Smt. K. Haritha, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 17/12/2025 घोषणा की तारीख / Pronouncement: 21/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: Both These Appeals Are Filed By M/S. Sgd Pharma India Private Limited (“The Assessee”), Feeling Aggrieved By The Separate Final Assessment Orders Passed By The Learned Assessing Officer (“Ld. Ao”) Under Section 143(3) Read With Sections 144C(13) Of The Income Tax Act, 1961 (“The Act") Dated 25.02.2022 & 27.07.2022 For A.Y 2017-18 & 2018-19 Respectively In Pursuance Of The Directions Issued By The Learned Dispute Resolution Panel (“Ld. Drp”). Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

respect of the international transaction relating to interest on External Commercial Borrowings ("ECB"). Based on the said order, the Ld. AO passed a draft assessment order dated 13.04.2021. 5. Aggrieved by the order of the Ld. AO, the assessee filed objections before the Ld. DRP. The Ld. DRP disposed