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

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.917/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2020-21) Shakti Hormann Private Limited, Hyderabad. Vs. Dcit, Circle-3(1), Hyderabad. Pan: Aadcs4024Q (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 15/10/2025 घोषणा की तारीख / Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Final Assessment Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The

TDS related disallowances; and (vii) prior year adjustments. After necessary verifications, the AO accepted the assessee's explanation on the issues other than the TP adjustment that was suggested by the TPO. 6. The AO thereafter issued a draft assessment order under section 144C(1) of the Act, dated 26/09/2023, wherein, after incorporating the TP adjustments, he proposed to assess

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

11 years as it retains the character of a loan. 7. In the case of CIT vs. South India Corporation (Agencies) Ltd., (cited supra), the Hon'ble High Court of Madras was seized of the issue as to whether the expenditure incurred on issue of debentures was capital or revenue and after considering the decision of the Hon'ble Supreme

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, 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.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

EPAM SYSTEMS INDIA PRIVATE 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.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

RAMKY INFRASTRUCTURE LIMITED, HYDERABAD,HYDERABAD vs. JCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2009-10 Ramky Infrastructure Ltd, Vs. Joint Commissioner Of Hyderabad. Income Tax, Pan:Aaacr8627B Circle 3(1), Hyderabad. (Appellant) (Respondent) Assessee By: Shri A.V. Raghuram. Revenue By: Shri Jeevan Lal Lavidiya, Dr Date Of Hearing: 15/11/2022 Date Of Pronouncement: 28/11/2022 O R D E R Per Laliet Kumar, J.M

TDS as per the relevant provisions of the Act. 7. Any other ground or grounds as may be urged at the time of hearing”. 3. The learned Counsel for the assessee submitted the following written submissions: “1. In the present case, the AO passed assessment orders for asst. years 2003-04 to 2009-10 on various dates denying the benefit

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 200(3) of the Act. The TDS statements are to be deposited quarterly i.e. quarter ending 30th June, 30th September, 31st December and 31st March of each financial year and the due date for furnishing the TDS statements is 15th July for the first quarter, 15th October for the second quarter, 15th January for the third quarter and 15th

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 200(3) of the Act. The TDS statements are to be deposited quarterly i.e. quarter ending 30th June, 30th September, 31st December and 31st March of each financial year and the due date for furnishing the TDS statements is 15th July for the first quarter, 15th October for the second quarter, 15th January for the third quarter and 15th

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 200(3) of the Act. The TDS statements are to be deposited quarterly i.e. quarter ending 30th June, 30th September, 31st December and 31st March of each financial year and the due date for furnishing the TDS statements is 15th July for the first quarter, 15th October for the second quarter, 15th January for the third quarter and 15th

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

11 is uncalled. Particularly when the issue under consideration is under challenge before another Appellate Authority. 33.4 The Hon’ble Kolkata High Court in CIT v. Coventory Spring & Co. Ltd. 257 ITR 632 had taken the view that “initial intimation merges into regular assessment and once proceedings for regular assessment under section 143(3) are commenced, there cannot

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

11,000 3,975 2,551 26Q 3 18.04.2022 154 19.04.2022 44,000 7,340 3,080 27EQ 1 30.06.2022 154 30.06.2022 566 35 27EQ 2 15.11.2021 200A/206CB 20.11.2021 573.75 27EQ 3 15.11.2021 200A/206CB 20.11.2021 60,800 4,667 27EQ 4 13.01.2022 154 13:01.2022 36,800 1,886 772 2,41,340 17,868 12,032 3. Apart from

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

11. | 310/Hyd./2025 | | | 2021-22 | Dated 26.12.2024 |\n| 12. | 311/Hyd./2025 | | | 2022-23 | 26.12.2024 |\n| 13. | 522/Hyd./2025 | Skanda Infra Projects, Kurnool. PIN 518002 PAN ABSFS7237C | The ACIT, Central Circle 2(3), HYDERABAD. PIN – 500 004 | 2019-20 | 26.12.2024 |\n| 14. | 523/Hyd./2025 | | | 2020-21 | 26.12.2024 |\n| 15. | 524/Hyd./2025 | | | 2021-22 | 06.01.2025 |\n| 16. | 525/Hyd./2025

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted the provisions of section 40(a)(ia) of the Act; and (ii) and though the assessee company had during the subject year carried out international transactions with its Associated Enterprises (AEs) of Rs.23,97,35,320/-, but the AO in the course

ITO (INTERNATIONAL TAXATION)-1, HYDERAABAD vs. DEENABABU KONDUBHATLA, HYDERABAD

Bench: Us :

TDS relating to Section 195. 3 3. During the course of assessment proceedings, the A.O. observed that the assessee had, during the subject year, sold two immovable properties, on which Long Term Capital Gain aggregating to Rs. 13,18,002/-, viz. (i). Property - I: Rs. 55,887/- and (ii). Property – II: Rs.12,62,115/- was disclosed in his return

NATIONAL ACADEMY OF CONSTRUCTION,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

Appeal is treated as allowed for statistical purposes in above terms

Bench: Shri A.Mohan Alankamony & Shri S.S.Godara

3 -: violation of Section 11(5) during the earlier A.Y.2002-2003. During the current year, assessee did not make any further investment in violation of Section 11(5). Further, such investment did not yield any income during the current year, However, stating that the violation continued in the current year, the learned Assessing Officer denied the claim of exemption u/s 11

THOTA RAMAIAH L/R T VASUNDHARA,HYDERABAD vs. ACIT, CIRCLE-4(1), , HYDERABAD

In the result, the appeal of the assessee is allowed

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

TDS Certificates etc. Ld. AR further submitted that section 40A(3) of the Act is applicable only to those expenditures which were incurred by the assessee with an intention to evade the tax and not applicable to genuine business payments made in the regular course of business. He relied on the decisions of Hon'ble High Court of Gujarat

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

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

11. The Assessing Officer having perused the books of account and records maintained by the Appellant and having verified them, without adverse findings specifically, should have invoked the provisions of section 145 of the Act. 12. The assessee has relied upon case-law of the Hyderabad Tribunal in the case of BHAGYANAGAR CONSTRUCTION (P) 124) VS INCOME TAX OFFICER vide