KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

10% to 14% for a period of 1 year to 4 years. Therefore, the assessee submitted that interest paid on customer advances was wholly and exclusively for the purpose of the business of the assessee and thus, allowable as a deduction. 7. The AO, however, was not convinced with the explanation furnished by the assessee. According to the AO, although

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

10% to 14% for a period of 1 year to 4 years. Therefore, the assessee submitted that interest paid on customer advances was wholly and exclusively for the purpose of the business of the assessee and thus, allowable as a deduction. 7. The AO, however, was not convinced with the explanation furnished by the assessee. According to the AO, although

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

10% to 14% for a period of 1 year to 4 years. Therefore, the assessee submitted that interest paid on customer advances was wholly and exclusively for the purpose of the business of the assessee and thus, allowable as a deduction. 7. The AO, however, was not convinced with the explanation furnished by the assessee. According to the AO, although

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

10% to 14% for a period of 1 year to 4 years. Therefore, the assessee submitted that interest paid on customer advances was wholly and exclusively for the purpose of the business of the assessee and thus, allowable as a deduction. 7. The AO, however, was not convinced with the explanation furnished by the assessee. According to the AO, although

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)

14. The learned counsel for the assessee Shri G. Srinivasa Rao, C.A. submitted that, the Ld. CIT(A) erred in confirming the disallowance made under 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

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)

14. The learned counsel for the assessee Shri G. Srinivasa Rao, C.A. submitted that, the Ld. CIT(A) erred in confirming the disallowance made under 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

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)

14. The learned counsel for the assessee Shri G. Srinivasa Rao, C.A. submitted that, the Ld. CIT(A) erred in confirming the disallowance made under 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

SRI SAI CONSTRUCTION CO,NIZAMABAD vs. DCIT., CIRCLE-1, NIZAMABAD

In the result appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

10% expenditure for want of evidences, but, the fact remains that, the ad-hoc disallowance of expenditure is beyond the scope of show cause notice issued by the learned PCIT. Therefore, from the above, it is abundantly clear that, the revision proceedings taken-up by the learned PCIT is not in accordance with law and, therefore, the Order

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

10. The company provides information Technology ('IT') enabled services and in this regard uses a number of computer software and IT maintenance services. During the year the Appellant has incurred expenses of Rs.52.32 crores on software and maintenance services. Most of the software and maintenance services are made by the ITA Nos.1613 & 1632/Hyd/2017 Page 19 parent company and allocated

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 :

14,80,6791- in para 4 of the assessment order is hereby deleted accordingly. The ground no. 5 pertains to grant of TDS credit, the AO is directed to verify and allow TDS credit as per law. The above ground is allowed to that extent accordingly. The Ground nos. 6 & 7 are consequential to the grounds adjudicated above, therefore needs

INDUR AVENUES AND FOODS PRIVATE LIMITED,NIZAMABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

10% to 14% for a period of 1 year to 4 years. Therefore, the assessee submitted that interest paid on customer advances was wholly and exclusively for the purpose of the business of the assessee and thus, allowable as a deduction. 8. The AO, however, was not convinced with the explanation furnished by the assessee. According to the AO, although

INDUR AVENUES AND FOODS PRIVATE LIMITED,NIZAMABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

10% to 14% for a period of 1 year to 4 years. Therefore, the assessee submitted that interest paid on customer advances was wholly and exclusively for the purpose of the business of the assessee and thus, allowable as a deduction. 8. The AO, however, was not convinced with the explanation furnished by the assessee. According to the AO, although

INDUR DEVELOPERS AND AGENCIES PRIVATE LIMITED ,VIJAYAWADA vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

10% to 14% for a period of 1 year to 4 years. Therefore, the assessee submitted that interest paid on customer advances was wholly and exclusively for the purpose of the business of the assessee and thus, allowable as a deduction. 8. The AO, however, was not convinced with the explanation furnished by the assessee. According to the AO, although

SKANDHANSHI DEVELOPERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

TDS, which attracts disallowance u/sec.40(a)(ia) of the Income Tax Act, 1961. Therefore, considering the overall scenario including relevant books of accounts maintained by the assessee and incriminating material found during the course of search observed that, the profit percentage of undisclosed turnover found during the course of search proceedings should be more than the profit percentage

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.:

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 by the Ld. AO on account of interest paid under section 201(1A) of the Act for delay

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 as mentioned in Section 40(a)(ia) of the Act r.w.s. first Proviso of Section 201(1) of the Act. The ld.CIT(A) has also held that in case the payee referred to in the first proviso to section 201(1) of the Act and had taken into account such return of income, then the assessee (Payee) shall

ANALOGICS TECH INDIA LIMITED ,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

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

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

10. This decision of the Hon'ble Apex Court declaring the law under the provision under section 36(1)(va) of the Act will take the retrospective effect, if not otherwise stated to be so specifically. In the decision, nothing contrary is indicated for any prospective effect only. It is, therefore clear that the law under section

S & P CAPITAL IQ (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, INTERNATIONAL TAXATION-2, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

10,799/- towards the 20% of TDS on the software license payment in the nature of royalty and also charged interest of Rs. 1,67,50,047/- under section 201(1A) of the Act. 3. Aggrieved by such an action of the learned Assessing Officer, assessee preferred an appeal before the learned CIT(A) and submitted that the matter