SLR INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

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

TDS deducted under Section 194C of the Act, which is evident from annexure forming part of notices issued under Section 142

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

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

TDS under Section 201(1A), belated payment of contribution to EPF and ESI, loans and advances given to related parties and expenditure incurred by the assessee under the head “trade discounts”, “seed purchases” and also amount debited under the head “ROC charges”. Consequent to the order passed by the learned PCIT under Section 263 of the Act, the A.O. issued

SKANDHANSHI INFRA PROJECTS INDIA PRIVATE LIMITED,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

142] the Assessing Officer may make an\nassessment in the manner provided in section 144?.\n6. 5. In view of the discrepancies noticed and also in the absence of any evidence,\nthe books of accounts maintained by the assessee cannot be relied upon. Hence, the\nassessee was issued a showcause notice requiring to showcause as to why the\nsame should

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

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERBAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED ,HYDERABAD vs. INCOME TAX OFFICERS ,WARD -1(2), HYDERABAD

In the result, appeal of the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2012-13 Country Club Hospitality & Vs. Income-Tax Officer, Ward Holidays Ltd., Hyderabad. – 1(2), Hyderabad. Pan – Aaacc 8276 B (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Rohit Mujumdar Date Of Hearing: 08/02/2022 Date Of Pronouncement: 17/02/2022

TDS which are relevant for the AY 2012-13. Whereas the language used in section 147 is that “where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. COASTAL PROJECTS PRIVATE LIMITED , HYDERABAD

In the result, the C.O. filed by the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS, Certificates issued and payment received from the contractor etc. The ADIT (Inv) had thoroughly verified and an appropriate intimation was sent by him while handing over the seized material to the assessment circle. Therefore, the primary facts were fully disclosed at the time of original assessment and the AO did not state in the satisfaction note the manner

KARTHIK KUMAR KYATHAM,NIZAMABAD vs. ITO, WARD-1, ADILABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1658/Hyd/2025

Section 192) WIPRO LIMITED 12 Amount paid or credited 904142 TDS-192 2. The assesse has filed return of income declaring income from salary (Gross salary Rs.9,04,142

KRISHNA CONSTRUCTIONS,NIRMAL vs. INCOME TAX OFFICER, WARD-1, NIRMAL

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1330/Hyd/2025 Assessment Year 2017-2018 Krishna Constructions The Income Tax Officer, Nirmal. Telangana. Ward-1, Vs. Pin – 504 106. Nirmal – 504 106. Pan Aapfk1280K Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri D Prabhakar Reddy, Advocate राज" व "ारा/Revenue By : Dr. Sachin Kumar,Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10.03.2026 घोषणा की तारीख/Pronouncement: 08.04.2026 आदेश/Order Per Vijay Pal Rao:

section 144A of the Act may be invoked in suitable cases. Further, to prevent fishing and roving enquiries in these cases, it is desirable that these cases are invariably picked up for review/inspection by the administrative authority. 9.8. In the present case, admittedly the same AO who had issued the notice u/s 143(2) of the Act, while issuing notice

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

142(1) of the Act. In response, the assessee company furnished explanations, supporting documents regarding the aforementioned multi-facet issues, viz., (i) reversal of provisions; (ii) deduction under section 43B of the Act; (iii) other income; (iv) sales commission; (v) Government grants; (vi) TDS

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 Credit of the transferor company to successor or transferee company even though the income of the transferor company is already considered by the successor company. 18.3 The Ld. AO erred in law and facts by not granting any TCS credit vis-à-vis INR 1,29,734/- as claimed by the Appellant in its Return of Income

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)

Section 142(1) of the Act were issued on 29.09.2022, 04.01.2023, 19.01.2023, and 28.07.2023, calling for details relating to business activities, ITR, financials, depreciation, ICDS compliance, TDS

TOSHIBA TRANSMISSION AND DISTRIBUTION SYSTEM (INDIA) PRIVATE LIMITED ,RUDRARAM vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-81), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri Manjunatha G. & Shri Prakash Chand Yadavआ.अपी.सं / Ita Tp No.103/Hyd/2020 (निर्धारण वर्ा / Assessment Year: 2015-16) Toshiba Transmission & Distribution Vs. Acit, Circle-8(1) Systems (India) Private Ltd. Hyderabad Hyderabad [Pan :Aaect6883F] अपीलधर्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Ms.Kranthi,Ar & Shri Kc Devdas, Ar रधजस्‍व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr

section 142(1) and 143(2) were issued to assessee. 3. During the course of assessment proceedings, the Assessing Officer ( AO) observed that the assessee company entered into international transactions of Rs.17,43,44,386/- and specified domestic transactions of Rs.8,59,38,647/- with associate enterprises(AE) during the year and accordingly with the prior approval of Pr.CIT