THE DCIT, CENTRAL CIRCLE - 2, HYDERABAD vs. M/S. ENGINEERS REDDY P. LTD, HYDERABAD

In the result, appeals of the assessee in ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

section 80IB(10) of the Act. In other words, the AO cannot reject the claim of deduction u/s.80IB(10) of the entire project for non-completion of the few buildings. We therefore set aside the order of Ld.CIT(A) and direct the AO to allow pro-rata deduction claimed u/s.80IB(10) in respect of project 'Kumar Padmalaya'. The grounds raised

JANAPRIYA ENGINEERS SYNDICATE LIMITED (FORMERLY KNOWN AS JANAPRIYA ENGINEERS SYNDICATE PVT. LTD.),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee in ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

section 80IB(10) of the Act. In other words, the AO cannot reject the claim of deduction u/s.80IB(10) of the entire project for non-completion of the few buildings. We therefore set aside the order of Ld.CIT(A) and direct the AO to allow pro-rata deduction claimed u/s.80IB(10) in respect of project 'Kumar Padmalaya'. The grounds raised

THE DCIT, CENTRAL CIRCLE - 2, HYDERABAD vs. M/S. ENGINEERS REDDY P. LTD, HYDERABAD

In the result, appeals of the assessee in ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

section 80IB(10) of the Act. In other words, the AO cannot reject the claim of deduction u/s.80IB(10) of the entire project for non-completion of the few buildings. We therefore set aside the order of Ld.CIT(A) and direct the AO to allow pro-rata deduction claimed u/s.80IB(10) in respect of project 'Kumar Padmalaya'. The grounds raised

DCIT, CENTRAL CIRCLE-1(2), HYDERABAD, HYDERABAD vs. JANAPRIYA ENGINEERS SYNDICATE LIMITED, HYDERABAD, HYDERABAD

In the result, appeals of the assessee in ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

section 80IB(10) of the Act. In other words, the AO cannot reject the claim of deduction u/s.80IB(10) of the entire project for non-completion of the few buildings. We therefore set aside the order of Ld.CIT(A) and direct the AO to allow pro-rata deduction claimed u/s.80IB(10) in respect of project 'Kumar Padmalaya'. The grounds raised

JANAPRIYA ENGINEERS SYNDICATE LIMITED (FORMERLY KNOWN AS JANAPRIYA ENGINEERS SYNDICATE PVT. LTD.),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee in ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

section 80IB(10) of the Act. In other words, the AO cannot reject the claim of deduction u/s.80IB(10) of the entire project for non-completion of the few buildings. We therefore set aside the order of Ld.CIT(A) and direct the AO to allow pro-rata deduction claimed u/s.80IB(10) in respect of project 'Kumar Padmalaya'. The grounds raised

TARAKARAMA EDUCATIONAL SOCIETY ,HYDERABAD vs. PR. COMMISSIONER OF INCOME TAX, CENTRAL, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

20-04-2021 O R D E R PER S.S.GODARA, J.M. : These four assessees’ appeals arise against the Pr.CIT(Central), Hyderabad’s separate orders; all dated 26-12- 2019 withdrawing their respective approvals in proceedings u/s.10(23C)(vi) of the Income Tax Act, 1961 [in short, ‘the Act’]. :- 2 -: ITA Nos. 318, 319, 320 & 321/Hyd/2020 Heard all assesses as well

AURORA EDUCATIONAL SOCIETY ,HYDERABAD vs. PR. COMMISSIONER OF INCOME TAX, CENTRAL, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

20-04-2021 O R D E R PER S.S.GODARA, J.M. : These four assessees’ appeals arise against the Pr.CIT(Central), Hyderabad’s separate orders; all dated 26-12- 2019 withdrawing their respective approvals in proceedings u/s.10(23C)(vi) of the Income Tax Act, 1961 [in short, ‘the Act’]. :- 2 -: ITA Nos. 318, 319, 320 & 321/Hyd/2020 Heard all assesses as well

KARSHAK VIDYA PARISHAD ,HYDERABAD vs. PR. COMMISSIONER OF INCOME TAX, CENTRAL, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

20-04-2021 O R D E R PER S.S.GODARA, J.M. : These four assessees’ appeals arise against the Pr.CIT(Central), Hyderabad’s separate orders; all dated 26-12- 2019 withdrawing their respective approvals in proceedings u/s.10(23C)(vi) of the Income Tax Act, 1961 [in short, ‘the Act’]. :- 2 -: ITA Nos. 318, 319, 320 & 321/Hyd/2020 Heard all assesses as well

CHURCH EDUCATINAL SOCIETY ,HYDERABAD vs. PR. COMMISSIONER OF INCOME TAX, CENTRAL, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

20-04-2021 O R D E R PER S.S.GODARA, J.M. : These four assessees’ appeals arise against the Pr.CIT(Central), Hyderabad’s separate orders; all dated 26-12- 2019 withdrawing their respective approvals in proceedings u/s.10(23C)(vi) of the Income Tax Act, 1961 [in short, ‘the Act’]. :- 2 -: ITA Nos. 318, 319, 320 & 321/Hyd/2020 Heard all assesses as well

DEPUTY COMMISSIONER OF INCOME TAX(IT)-II, HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, SECUNDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.725/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2015-16) Dy. C.I.T (It)-Ii Vs. Sew Infrastructure Ltd Hyderabad Secunderabad Pan:Aadcs4061P (Appellant) (Respondent) राज" व "ारा/Revenue By: Shri B Bala Krishna, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate सुनवाई की तारीख/Date Of Hearing: 22/10/2024 घोषणा की तारीख/Pronouncement: 28/10/2024 आदेश/Order

10% TDS as per DTAA is contrary to provisions of section 206AA of the I.T. Act, 1961 and thus, computed short deduction of TDS by applying TDS @ 20

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)

10,580/-. A search and seizure operation u/s 132 of the Income-tax Act, 1961 (for short “the Act”) was conducted in the case of the assessee on 27.09.2016. Notice u/s 153A was issued to the assessee on 06.03.2020, however, no return was filed in response. The A.O. noted that, an expenditure of Rs. 43,41,133/- booked

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)

10,580/-. A search and seizure operation u/s 132 of the Income-tax Act, 1961 (for short “the Act”) was conducted in the case of the assessee on 27.09.2016. Notice u/s 153A was issued to the assessee on 06.03.2020, however, no return was filed in response. The A.O. noted that, an expenditure of Rs. 43,41,133/- booked

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)

10,580/-. A search and seizure operation u/s 132 of the Income-tax Act, 1961 (for short “the Act”) was conducted in the case of the assessee on 27.09.2016. Notice u/s 153A was issued to the assessee on 06.03.2020, however, no return was filed in response. The A.O. noted that, an expenditure of Rs. 43,41,133/- booked

HCC CP PL JV,HYDERABAD vs. INCOME TAX OFFICER, WARD-14(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2018-19 Hcc Cp Pl Jv, Vs. The Income Tax Officer, Ward –14(1), Hyderabad. Hyderabad. Pan : Aaaah5541G. (Assessee) (Respondent) Assessee By: Shri Gvn Hari, Advocate (Appeared Through Hybrid Mode) Revenue By: Shri Srinath Sadanala, Sr.Dr Date Of Hearing: 06.02.2025 Date Of Pronouncement: 24.02.2025

10. We have heard both the parties, perused the material on record and gone through the orders of the authorities below. There is no dispute with regard to the fact that the assessee is a JV / Consortium with two constituent partners i.e., HCCL and CPL. The assessee company was awarded a contract by NFR, which deducted TDS on the gross

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.:

10,265/- made by the Ld. AO on account of interest paid under section 201(1A) of the Act for delay in deposit of tax deducted at source (“TDS”). The Ld. AR contended that such interest is compensatory Page 3 of 20

LYCOS INTERNET LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

Section under which TDS made (3) TDS remitted (4) Date remittance (5) of 27. Details of contract/sub-contracts taken/given during the year and copies of agreements relating to such contracts. 28. Please furnish names and complete mailing address of the parties to whom sub contracts were awarded, details of work cost, transportation cost and labor charges were paid. 29. Details

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

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

section 40(a)(i) of the Act. nature. 15. Accordingly, it is stated that the issue in case of Wipro Ltd. was whether the payment was for computer software amounted to royalty and whether TDS was applicable on the same. However, in the present facts of the Appellant, the issue is not whether the payment for obtaining licenses of software