BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 40(a)(ia) of the Act, an amount of Rs. 13,02,340/- @ 30% of total expenditure incurred towards payment to subcontractors, Shankarapally and Bathini Infra on the basis of the seized material without appreciating the fact that, the assessee had deducted TDS

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

02,323/- and assessed the total income of the assessee at Rs.9,74,14,421/-. 5. Aggrieved with the final order of the Ld. AO, the assessee preferred an appeal before this Tribunal. The Learned Authorized Representative (“Ld. AR”) submitted that the Ground No.1 of the assessee pertains to disallowance of Rs.2,10,265/- made

AMARA RAJA POWER SYSTEMS LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

02,114/-, but had\ndeducted tax at source (TDS) under Section 194C of the Act of Rs.\n1,36,78,178/- on the contract

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD, HYDERABAD vs. SUSHEE PRASAD JV, HYDERABAD

In the result, the appeal of the revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 The Assistant Commissioner Of Vs. Sushee Prasad Jv, Hyderabad, Income Tax, Circle – 6(1), Plot No.246/A/2, Road Hyderabad. No.12, Mla Colony, Banjara Hills, Telangana – 500034. Pan : Aapas3540R. (Appellant) (Respondent) Assessee By: Shri S. Ramarao, Advocate. Revenue By: Shri Sesha Srinivas, Cit-Dr Date Of Hearing: 06.03.2024 Date Of Pronouncement: 12.03.2024

TDS u/s 194C of the I.T. Act and deducted tax at source. 5. The Ld. CIT(A) erred in law and on facts in granting relief by not considering the fact that the case of the assessee is not that of non- deduction on contract payments but a case of tax deducted at source and not fully deposited within

R.K DISTILLERIES PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

section 37BA for denying the benefit of TDS during the year under consideration. This part of the Rule provides that the credit for TDS shall be given to the person to whom payment has been made or credit has been given on the basis of information relating to TDS furnished by the deductor. What is material for sub-rule

INCOME TAX OFFICER, WARD-1(2), HYDERABAD vs. ATHENA GLOBAL TECHNOLOGIES LIMITED (FORMERLY M/S VJIL CONSULTING LIMITED), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TDS compliances. ITA No.895 896 and 4 1266/Hyd/2018 e) addition of 50% of sales promotion expenses of Rs.13,13,955/- amounting to Rs.6,56,978/- due to non- production of bills and vouchers. f) addition of Rs.1,27,840/- on account of depreciation due to non-submission of bills in support of additions of fixed assets during the year under

ATHENA GLOBAL TECHNOLOGIES LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(4), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TDS compliances. ITA No.895 896 and 4 1266/Hyd/2018 e) addition of 50% of sales promotion expenses of Rs.13,13,955/- amounting to Rs.6,56,978/- due to non- production of bills and vouchers. f) addition of Rs.1,27,840/- on account of depreciation due to non-submission of bills in support of additions of fixed assets during the year under

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-8(1), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TDS compliances. ITA No.895 896 and 4 1266/Hyd/2018 e) addition of 50% of sales promotion expenses of Rs.13,13,955/- amounting to Rs.6,56,978/- due to non- production of bills and vouchers. f) addition of Rs.1,27,840/- on account of depreciation due to non-submission of bills in support of additions of fixed assets during the year under

MADHUCON SINO HYDRA JV ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1344, 1311 & 1312/Hyd/2018 (निर्धारण वर्ा/Assessment Years:2012-13, 2013-14 & 2014-15) M/S. Madhucon Sino Hydro Jv, Hyderabad. ….Appellant. Pan:Aanfm1451G Vs. 1. Dy. Commissioner Of Income Tax, Circle-2(1), Hyderabad. 2. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. 3. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. ….Respondents.

02,365/-. 3. The Ld. CIT(A) erred in not appreciating the entire receipt are shown as income in the hands of assessee JV. 4. The Ld. CIT(A) erred in not appreciating the fact that assessee is eligible for credit of TDS as per provisions of section

MADHUCON SINO HYDRO JV,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1344, 1311 & 1312/Hyd/2018 (निर्धारण वर्ा/Assessment Years:2012-13, 2013-14 & 2014-15) M/S. Madhucon Sino Hydro Jv, Hyderabad. ….Appellant. Pan:Aanfm1451G Vs. 1. Dy. Commissioner Of Income Tax, Circle-2(1), Hyderabad. 2. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. 3. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. ….Respondents.

02,365/-. 3. The Ld. CIT(A) erred in not appreciating the entire receipt are shown as income in the hands of assessee JV. 4. The Ld. CIT(A) erred in not appreciating the fact that assessee is eligible for credit of TDS as per provisions of section

INCOME TAX OFFICER, WARD-14(1), HYDERABAD vs. MADHUCON SINO HYDRO JV, HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1344, 1311 & 1312/Hyd/2018 (निर्धारण वर्ा/Assessment Years:2012-13, 2013-14 & 2014-15) M/S. Madhucon Sino Hydro Jv, Hyderabad. ….Appellant. Pan:Aanfm1451G Vs. 1. Dy. Commissioner Of Income Tax, Circle-2(1), Hyderabad. 2. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. 3. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. ….Respondents.

02,365/-. 3. The Ld. CIT(A) erred in not appreciating the entire receipt are shown as income in the hands of assessee JV. 4. The Ld. CIT(A) erred in not appreciating the fact that assessee is eligible for credit of TDS as per provisions of section

MADHUCON SINO HYDRO JV,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1344, 1311 & 1312/Hyd/2018 (निर्धारण वर्ा/Assessment Years:2012-13, 2013-14 & 2014-15) M/S. Madhucon Sino Hydro Jv, Hyderabad. ….Appellant. Pan:Aanfm1451G Vs. 1. Dy. Commissioner Of Income Tax, Circle-2(1), Hyderabad. 2. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. 3. Asst. Commissioner Of Income Tax, Circle-14(1), Hyderabad. ….Respondents.

02,365/-. 3. The Ld. CIT(A) erred in not appreciating the entire receipt are shown as income in the hands of assessee JV. 4. The Ld. CIT(A) erred in not appreciating the fact that assessee is eligible for credit of TDS as per provisions of section

VISHAL INFRASTRUCTURE LIMITED,SECUNDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

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

section 143(1) of the Act at Rs.23,81,60,336/- as\nagainst the returned income of Rs.23,77,97,210/- for the purpose of\ncomputation of the total assessed income. As submitted by the Ld.\nAR, the income of Rs.23,81,60,336/- u/s.143(1) of the Act has been\narrived after inclusion of Rs.3

SABIR, SEW 7 PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

TDS under Section 194C is applicable to\npayments made by broadcasting and telecasting companies\n(including production of programs for broadcasting or telecasting)\nto advertising agencies and payments by advertising agencies to\nmedia owners (such as Doordarshan, newspapers, etc.) and it can\nnot be extended the activities of the assessee.\n\n14.\nIt was submitted that after the issuance

SABIR, SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

TDS under Section 194C is applicable to\npayments made by broadcasting and telecasting companies\n(including production of programs for broadcasting or telecasting)\nto advertising agencies and payments by advertising agencies to\nmedia owners (such as Doordarshan, newspapers, etc.) and it can\nnot be extended the activities of the assessee.\n\n14. It was submitted that after the issuance

SABIR , SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

TDS under Section 194C is applicable to\npayments made by broadcasting and telecasting companies\n(including production of programs for broadcasting or telecasting)\nto advertising agencies and payments by advertising agencies to\nmedia owners (such as Doordarshan, newspapers, etc.) and it can\nnot be extended the activities of the assessee.\n14. It was submitted that after the issuance

CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

In the result, all the appeals of the assessee are allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

TDS under Section 194C is applicable to payments made by broadcasting and telecasting companies (including production of programs for broadcasting or telecasting) to advertising agencies and payments by advertising agencies to media owners (such as Doordarshan, newspapers, etc.) and it can not be extended the activities of the assessee. 14. It was submitted that after the issuance of the circular

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED, HYDERABAD

Bench: Shri S.S. Godara & Shri L. P. Sahu(Through Virtual Hearing)

TDS thereupon. And also that hon'ble apex court’s decision (2011) 5 SCR 897 Urviben Chiragbhai Sheth Vs. Vijaybhai Shambubhai Joranputra & Ors holds that such a concession is made, the same is sacrosanct if made before a Court of Record only. We therefore uphold the CIT(A)’s action in deleting the RCI payment disallowance of Rs.6