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)

11,90,000/- made under Section 69C of the Act. 31. The next issue that came up for our consideration from Ground No. 5 of the assessee’s appeal is disallowance of Rs. 2,91,31,153/- under Section 40(a)(ia) of the Income-tax Act, 1961 for non-deduction of TDS

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)

11,90,000/- made under Section 69C of the Act. 31. The next issue that came up for our consideration from Ground No. 5 of the assessee’s appeal is disallowance of Rs. 2,91,31,153/- under Section 40(a)(ia) of the Income-tax Act, 1961 for non-deduction of TDS

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)

11,90,000/- made under Section 69C of the Act. 31. The next issue that came up for our consideration from Ground No. 5 of the assessee’s appeal is disallowance of Rs. 2,91,31,153/- under Section 40(a)(ia) of the Income-tax Act, 1961 for non-deduction of TDS

RAJESH DADU,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2019-20 Shri Rajesh Dadu Vs. Dy.C.I.T. Hyderabad Circle 4(1) Pan:Aerpd6385C Hyderabad (Appellant) (Respondent) Assessee By: Shri B. Radha Krishna, Ca Revenue By: Shri Kprr Murthy, Cit(Dr) Date Of Hearing: 23/03/2023 Date Of Pronouncement: 31/03/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 9.11.2022 Of The Learned Cit (A)-Nfac, Relating To A.Y.2019-20. 2. Although A Number Of Grounds Have Been Raised By The Assessee, However, These All Relate To The Order Of The Cit (A)- Nfac In Upholding The Order Passed By The Cpc In Not Giving Credit Of Tds Amount Of Rs.10,11,000/-.

TDS of Rs.10,11,000/- under the provisions of section 1941A of the Act, but the same was not deposited

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

TDS on the gross contract receipts as per 11 Section 194C of the Act, and reported it in the name

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

11 ITA.No.670/Hyd./2025 consequent to order passed under section 263, where, the Assessing Officer has accepted the issue of debit to Profit and Loss account under the Head “Government Recoveries” and also difference in turnover as noticed by the learned PCIT. The Assessing Officer had also accepted the issue of expenditure under the Head “Rents/JCB/Tipper/Crane” on the issue

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

TDS and further\ndisallowance of EPF & ESI under Section 36(1)(va) for Rs.\n3,66,095/-, addition towards disallowance of interest expenditure\nunder Section 36(1)(iii) for Rs. 11

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.:

TDS under section 192 of the Act, and since the assessee has failed to deduct tax, the disallowance under section 40(a)(i) of the Act has rightly been made and should be upheld. 11

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE 3(4), HYDERABAD

TDS),\nCPC, Ghaziabad, considering the TDS/TCS statements passed orders under\nsection(s) 200A/206CB r.w.s 154 r.w.s 200A for the respective quarters,\nwherein demands under section 201(1A), 234E and 220(2) were raised, as\nunder:\nForm No.\nQuarter\nDate of Date of\nfiling of\nfiling of\nquarterly rectification\nreturn\nOrder u/s.\nby CPC\nDate of 234E

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(4), HYDERABAD

Accordingly, the appeal filed by the assessee company, being devoid and bereft of any substance, is dismissed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1236 & 1237/Hyd/2025 ("नधा"रण वष"/Assessment Year:2021-22 & 2022-23) Vivimed Labs Limited, Vs. Dcit, Hyderabad. Central Circle-3(4), Pan: Aaacv6060A Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई क" तार"ख/Date Of 05/01/2026 Hearing: घोषणा क" तार"ख/Date Of 21/01/2026 Pronouncement: आदेश / Order

TDS) and remitted the same in the Government Treasury as per the extant provisions. 11. Apropos the claim of the assessee company that it was not to be held as an assessee-in-default under section

SWARNA EDUCATIONAL ACADEMY,HYDERABAD vs. ITO, EXEMPTION WARD-1(4), HYDERABAD

In the result, the appeal of assessee is dismissed as infructuous

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS and had filed return in Form Type 7 and has not claimed any deduction exemptions under section 11 or clauses

HYDERABAD METROPOLITAN DEVELOPMENT AUTHORITY,HYDERABAD vs. DCIT, EXEMPTION CIRCLE-1(1), HYDERABAD

The appeal of the revenue is partly allowed for statistical

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.581/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. Hyderabad Metropolitan Development Authority, Hyderabad. Pan:Aaalh0058D …..Appellant. Vs. Asst. Commissioner Of Income Tax (Exemptions), Circle-1(1), Hyderabad. …..Respondent. आ.अपी.सं /Ita No.568/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) Asst. Commissioner Of Income Tax (Exemptions), Circle-1(1), Hyderabad. …..Appellant. Vs. M/S. Hyderabad Metropolitan Development Authority, Hyderabad. …..Respondent.

TDS as application of income cannot be ITA Nos.581 & 568/Hyd/2024 15 allowed. The Ld. AR contended that, in such cases the amount not available with the assessee should be considered as applied for the purpose of section 11

ACIT (EXEMPTIONS), CIRCLE-1(1), HYDERABAD vs. HYDERABAD METROPOLITAN DEVELOPMENT AUTHORITY, HYDERABAD

The appeal of the revenue is partly allowed for statistical

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.581/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. Hyderabad Metropolitan Development Authority, Hyderabad. Pan:Aaalh0058D …..Appellant. Vs. Asst. Commissioner Of Income Tax (Exemptions), Circle-1(1), Hyderabad. …..Respondent. आ.अपी.सं /Ita No.568/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) Asst. Commissioner Of Income Tax (Exemptions), Circle-1(1), Hyderabad. …..Appellant. Vs. M/S. Hyderabad Metropolitan Development Authority, Hyderabad. …..Respondent.

TDS as application of income cannot be ITA Nos.581 & 568/Hyd/2024 15 allowed. The Ld. AR contended that, in such cases the amount not available with the assessee should be considered as applied for the purpose of section 11

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

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

TDS credits without offering the corresponding income to tax by not taking cognizance of the submissions made by the Appellant explaining that such income would have been offered to tax either in the current year or in earlier years or in the subsequent years, depending upon the revenue recognized in the books of accounts on an accrual basis

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

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

11. Penalty Proceedings On the facts and circumstances of the case and in law, the Ld. TPO / Ld. AO / Ld. DRP have erred in initiating penalty proceedings under Section 270A and 271AA, without considering the fact that the aforesaid transfer pricing adjustment is on account of difference of opinion. 5 Gainsight Software Private Limited The Appellant craves leave

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

11 July 2022 issued by Transfer Pricing Officer (TPO) u/s 92CA of the Act, in so far as it is prejudicial to the Appellant, is contrary to law, facts and circumstances of the case. Transfer Pricing Adjustment 2. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

11 July 2022 issued by Transfer Pricing Officer (TPO) u/s 92CA of the Act, in so far as it is prejudicial to the Appellant, is contrary to law, facts and circumstances of the case. Transfer Pricing Adjustment 2. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price

CYIENT LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2021-22 Cyient Limited, Vs. The Deputy Commissioner Of Income Tax, Circle 1 (1), Hyderabad. Hyderabad. Apn : Aaac14887J

11 18. We find that the assessee has furnished list of names of employees, their addresses and PAN numbers and the DRP without verifying the facts, simply sustained addition. We find that as per Section 192 of the Act, the employer / payer is required to deduct TDS

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. IL & FS ENGINEERING & CONSTRUCTIONS CO. LIMITED , HYDERABAD

11,365/-. The appellant had also filed a revised\nreturn on 17.04.2009 in terms of provisions of section 139(5) of the\nIncome Tax Act, 1961 (“the Act”) and declared a total income of\nRs.110,63,44,274/- and claimed a refund of Rs.14,40,86,966/-. The\nreturn was further revised on 26.03.2010, by declaring a total\n5\nITA