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)

133/- booked by the assessee attracts the provisions of section 40(a)(ia) of the Act, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49

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)

133/- booked by the assessee attracts the provisions of section 40(a)(ia) of the Act, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49

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)

133/- booked by the assessee attracts the provisions of section 40(a)(ia) of the Act, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49

DIWAKAR LOGISTICS ,TADIPATRI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year:2014-15 M/S.Diwakar Logistics Vs. A.C.I.T Tadipatri Circle – 1 Pan:Aahfd0549E Anantapur (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri T. Sunil Goutam, Dr Date Of Hearing: 02/06/2022 Date Of Pronouncement: 05/08/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.12.2019 Of The Learned Cit (A)-Kurnool, Relating To A.Y.2014-15. 2. Fact Of The Case, In Brief, Are That The Assessee Is A Partnership Firm Engaged In The Business Of Transportation Of Goods & Filed Its Return Of Income On 29.11.2014 Declaring Total Income Of Rs.31,90,390/-. The Case Was Selected For Scrutiny. During The Course Of Assessment Proceedings, The Assessing Officer Noted That The Assessee Has Debited Finance Charges Of Rs.2,81,642/- & Transportation Charges Paid To Others Of Rs.74,57,350/-. The Assessing Officer Asked The Assessee To Page 1 Of 8

133(6) of the Act from those companies. 7.1. So far as the transportation charges are concerned, the learned Counsel for the assessee referring to various decisions including the decision of the Coordinate Bench of the Tribunal in assessee’s own case for the A.Y 2013-14 submitted that the Tribunal has deleted such addition on the ground that

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

6. That the facts and circumstances of the case, DRP is not justified in confirming the ALP of fly ash at Rs. 65.76/- per ton, determined without considering the freight component s part of landed cost of fly-ash, and making an adjustment of Rs. 60,90,830/-. 7. That in the facts and circumstances of the case

KCVR INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.986/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2021-22) Kcvr Infra Projects Private Vs. Asstt. Cit Limited Circle 2(2) Hyderabad Hyderabad Pan: Aaeck2457N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C A M.V. Prasad राज" व "ारा/Revenue By:: Shri Ranjan Agrawala, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Pronouncement: 26/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Kcvr Infra Projects Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) Dated 29.03.2025 For The A.Y 2021-22. 2. At The Outset, It Is Observed That The Appeal Has Been Filed Before Us With A Delay Of Three Days. The Assessee Has Filed A Condonation Petition Along With A Copy Of Affidavit Explaining The Cause Of Delay. The Learned Authorized Representative (“Ld. Ar”)

TDS was duly deducted by the assessee on these payments in accordance with the provisions of the Act. Further, in response to notice under section 133(6

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

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.891/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2021-22) Country Club Hospitality Vs. Deputy Commissioner & Holidays Limited, Of Income Tax, Hyderabad. Circle-1(1), Pan: Aaacc8276B Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (For Short, “Cit(A)”), Dated 22.04.2025, Which In Turn Arises From The Assessment Order Passed By The Ao Under Section 143(3) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 26.12.2022 For Ay 2021-22. The Assessee Company

TDS) under Section(s) 194H/194C of the Act. The AO to verify the authenticity of the subject payments issued notice u/s 133(6

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

133(6) of the Act from various banks. 7) The Ld. TPO/DRP/A.O. has erred in proposing/confirming the disallowance of Rs. 38,55,85,183/-u/s. 40(a)(ia) of the Act on account of non-deduction of tax from salary paid to it's employees. 8) The Ld. TPO/DRP/A.O. has failed to appreciate that the reference made

INCOME TAX OFFICER (INTERNATIONAL TAXATION)-1, HYDERABAD vs. ARUNA GULLAPALLI, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Income Tax Officer, Vs. Aruna Gullapalli, (International Taxation) – 1, Hyderabad. Hyderabad. Pan No.Bfhpg9489L. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Kumar Adithya Date Of Hearing: 23.01.2023 Date Of Pronouncement: 31.01.2023

6 Rs. 1,81,90,250/- vide cheque No.896026 dated 28-04-2016, drawn ICICI bank which is including of TDS u/s 194IA. 12.1 Thus, the appellant has factually demonstrated, that the entire sale consideration received on sale of plot was reinvested in a residential property, though the legal formalities of getting the property in the appellant’s name

PRASANTH PUTTAMAREDDY,NELLORE vs. INCOME TAX OFFICER, WARD-1, NELLORE

In the result, the appeal filed by the assessee in ITA

Bench: the Ld. CIT(A).

TDS was deducted under Section 194IA of the Income-tax Act, 1961. It was further noticed that, the assessee had not filed the return of income for the assessment year 2016-17, and in the absence of return of income, the source of investment towards purchase of the property remained unexplained. The A.O. issued notice under Section

PRASANTH PUTTAMAREDDY,NELLORE vs. INCOME TAX OFFICER, WARD-1, NELLORE

In the result, the appeal filed by the assessee in ITA

Bench: the Ld. CIT(A).

TDS was deducted under Section 194IA of the Income-tax Act, 1961. It was further noticed that, the assessee had not filed the return of income for the assessment year 2016-17, and in the absence of return of income, the source of investment towards purchase of the property remained unexplained. The A.O. issued notice under Section

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

133 under the normal provisions of the Act and a tax demand towards dividend distribution tax ('DDT') amounting to INR 4l,72,50,334 along with interest levied under Section 1I5P of the Act for an amount of INR 16,88,87,040, is contrary to the facts and circumstances of the case and in law and is liable

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

133 under the normal provisions of the Act and a tax demand towards dividend distribution tax ('DDT') amounting to INR 4l,72,50,334 along with interest levied under Section 1I5P of the Act for an amount of INR 16,88,87,040, is contrary to the facts and circumstances of the case and in law and is liable

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, ANANTAPUR vs. SAVEERA HOSPITAL PRIVATE LIMITED , ANANTAPUR

In the result, appeals of the Revenue are accordingly allowed and consequently the cross objections preferred by the assessee are dismissed

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

section 133(6) of the Act from any person on presumption that the said person is a shareholder. Further according to the learned Assessing Officer there is a discrepancy in the letters dated 10/10/2017 and 19/12/2017 in respect of the number of shares proposed to be issued on various dates to various shareholders. Learned Assessing Officer has given the details

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, ANANTAPUR vs. SAVEERA HOSPITAL PRIVATE LIMITED, ANANTAPUR

In the result, appeals of the Revenue are accordingly allowed and consequently the cross objections preferred by the assessee are dismissed

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

section 133(6) of the Act from any person on presumption that the said person is a shareholder. Further according to the learned Assessing Officer there is a discrepancy in the letters dated 10/10/2017 and 19/12/2017 in respect of the number of shares proposed to be issued on various dates to various shareholders. Learned Assessing Officer has given the details

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

6 of Revenue’s appeal are general in nature and do not need any specific adjudication. 58. Insofar as Ground No. 2 of assessee’s appeal is concerned, same relates to the computation of book profits under section 115JB of the Act. We find that it is identical to ground of appeal No.2 in ITA No. 645/Hyd/2020. We have already

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

6 of Revenue’s appeal are general in nature and do not need any specific adjudication. 58. Insofar as Ground No. 2 of assessee’s appeal is concerned, same relates to the computation of book profits under section 115JB of the Act. We find that it is identical to ground of appeal No.2 in ITA No. 645/Hyd/2020. We have already

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

6 of Revenue’s appeal are general in nature and do not need any specific adjudication. 58. Insofar as Ground No. 2 of assessee’s appeal is concerned, same relates to the computation of book profits under section 115JB of the Act. We find that it is identical to ground of appeal No.2 in ITA No. 645/Hyd/2020. We have already

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

6 of Revenue’s appeal are general in nature and do not need any specific adjudication. 58. Insofar as Ground No. 2 of assessee’s appeal is concerned, same relates to the computation of book profits under section 115JB of the Act. We find that it is identical to ground of appeal No.2 in ITA No. 645/Hyd/2020. We have already