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

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

Section 143(1) of the Act was issued to the assessee on 18.05.2020 by which a sum of Rs.1,85,76,482/- was disallowed on account of assessee's contribution under the ESI and PF and the total income of the assessee was determined at Rs.1,85,76,482/- and the tax payable on this income was computed at Rs.55

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

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

143(3B) on 09-04-2021, and relevant notices issued under Section 142(1) of the Act on various dates, submitted that the case was selected for scrutiny to verify the genuineness of the expenditure which covers sub-contract expenditure incurred in the name of the above two persons. The A.O. issued a specific notice under Section 142(1), dated

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

Section 80IA(4)(i). and accordingly was eligible for deduction in respect of profits derived therefrom. 5. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred by not following the decisions of the jurisdictional bench of Hon'ble ITAT and various other judicial authorities in a number of cases, including

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

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

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

TDS on the royalty payment. However, the Special Bench in the case of Merilyn Shipping & Transports (supra) held that the word "payable" used in section 40(a)(ia) of the Act has to be given its natural meaning and going by strict interpretation the section 40(a)(ia) of the Act is applicable only to expenditure which is payable

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

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

TDS on the royalty payment. However, the Special Bench in the case of Merilyn Shipping & Transports (supra) held that the word "payable" used in section 40(a)(ia) of the Act has to be given its natural meaning and going by strict interpretation the section 40(a)(ia) of the Act is applicable only to expenditure which is payable

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

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

TDS on the royalty payment. However, the Special Bench in the case of Merilyn Shipping & Transports (supra) held that the word "payable" used in section 40(a)(ia) of the Act has to be given its natural meaning and going by strict interpretation the section 40(a)(ia) of the Act is applicable only to expenditure which is payable

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)

143(2) of the Income-tax Act, 1961 dated 29.06.2021 was issued and served upon the assessee. Subsequently, the case was transferred to the Regional e-Assessment Centre under the Faceless Assessment Scheme, 2019. During the assessment proceedings, several notices under 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

HEALTHWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.888/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Healthware Pvt. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 2(1), Hyderabad. Hyderabad. Pan:Aabch2124A (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri C S Subrahmanyam, C.A. & Shri V Siva Kumar,Advocate रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 16/09/2025 घोर्णध की तधरीख/Pronouncement: 19/09/2025

TDS and accordingly claimed deduction of Rs.23,67,760/- in its return. However, the Centralised Processing Centre (“CPC”), while processing the return under section 143

PATEL SEW JOINT VENTURE,TELANGANA vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, the cross-objection filed by the assessee is dismissed

Section 143(1) of the Act, and intimation dated 14.02.2024 was issued, where the A.O. has not allowed credit for TDS

ACIT., CIRCLE-6(1), HYDERABAD vs. PATEL SEW JOINTVENTURE, HYDERABAD

In the result, the cross-objection filed by the assessee is dismissed

Section 143(1) of the Act, and intimation dated 14.02.2024 was issued, where the A.O. has not allowed credit for 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)

143(3) read with section 144C(13) read with section 144B of the Act, dated 06 December 2024 is illegal and void in as much as it is barred by limitation as the order is passed beyond the time limit prescribed under section 153 of the Act and therefore the order, is liable to be set aside. Grounds relating

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

TDS provisions under section 194C of the Act and consequent non- disallowance of expenditure under section 40(a)(ia) of the Act. Therefore, it is necessary for us to examine the assumption of jurisdiction by the learned PCIT, in light of relevant evidences placed by the Counsel for the Assessee, to justify it’s case. 13. Admittedly, the original assessment

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

Bench: Shri Manjunatha G.\Nand\Nshri Ravish Sood\Nआ.अपी.सं /Ita No.917/Hyd/2024\N(निर्धारण वर्ष/Assessment Year:2020-21)\Nshakti Hormann Private\Nlimited,\Nhyderabad.\Nvs. Dcit,\Ncircle-3(1),\Nhyderabad.\Npan: Aadcs4024Q\N(Appellant)\N(Respondent)\Nनिर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao,\Nca\Nराजस्व द्वारा / Revenue By: Ms. U. Mini Chandran,\Ncit-Dr\Nसुनवाई की तारीख /Date Of Hearing: 15/10/2025\Nघोषणा की तारीख / Date Of 19/12/2025\Npronouncement:\Nआदेश / Order\Nper. Ravish Sood, J.M:\Nthe Present Appeal Filed By The Assessee Company Is Directed\Nagainst The Final Assessment Order Passed By The Assessing Officer (For\Nshort, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The\Nincome Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The\N Assessment Year (Ay) 2020-21. The Assessee Company Has Assailed\Nthe Impugned Order Passed By The Cit(A) On The Following Grounds Of\Nappeal Before Us:\N1. On The Facts & In The Circumstances Of The Case, The Final Assessment\Norder Passed U/S 143(3) R.W.S.144C(13) Of The Act Dated 25.07.2024 By\Nthe Ao & Also The Order Passed U/S 92Ca (3) Dt 30.07.2023 By The Tpo\Nare Bad In The Eyes Of Law & Thus, Unsustainable To The Test Of Appeal.\N2.0 The Final Assessment Order Passed U/S 143(3) R.W.S.144C(13) R.W.S.144B\Nis Beyond The Time Limit Prescribed U/S 153 Of The Act.\N2.

TDS related\ndisallowances; and (vii) prior year adjustments. After necessary\nverifications, the AO accepted the assessee's explanation on the issues\nother than the TP adjustment that was suggested by the TPO.\n6. The AO thereafter issued a draft assessment order under section\n144C(1) of the Act, dated 26/09/2023, wherein, after incorporating the\nTP adjustments, he proposed to assess

AMARA RAJA POWER SYSTEMS LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

section 143(3) rws 144B on 26.09.2022 contains errors\nprejudicial to the Interests of revenue. It was found from the Form 3CD report filed by\nthe assessee that the assessee company had made payments to the contractors to the\ntune of Rs.335,23,02,114/-. However, it has deducted TDS

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.:

143(3) read with section 144C(13) of the Act on 31.10.2023, making the additions on account of Disallowance of interest paid under section 201(1A) of the Act of Rs.2,10,265/-, Disallowance of lead role expenditure of Rs.19,58,509/-, Disallowance of payment made to M/s. Antony Burchell of Rs. 3,08,08,089/-, Disallowance under section 44DA

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

143 (3) r.w.s. 147 was completed on 10-112017 relating to AY 2010-11. Thus, the assessment was completed after 4 years from the end of the relevant assessment year i.e 2010-11. The first proviso to section 147 stipulates that the income chargeable to tax has escaped assessment on account of failure of the assessee to disclosure fully