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)

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 to corporate tax: 2. Ground 2: Erroneous disallowance of business support

SIVA SANKARA REDDY TUNGA,HYDERABAD. vs. ITO., WARD - 14(1), HYDERABAD.

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

Bench: Us:

TDS Statement): Rs.1,25,775/-; and (iv) time deposit exceeding Rs.2 lakhs or more with Andhra Bank: Rs.26,00,000/- , but had not filed his return of income for the subject year, i.e., AY 2016- 17, issued notice under section 148A(b) of the Act. Thereafter, the AO passed an order under section 148A(d) of the Act, dated 25/03/2023

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

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

TDS and VAT payable under section 43B of the Act: Rs. 6,08,694/-; and (v) addition of Rs.3,34,246/- on account of estimated profit on undisclosed sales: Rs.3,34,246/-, but at the same time declined the assessee’s claim regarding the validity of jurisdiction that was assumed by the AO, while initiating proceedings under section

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

section 144B of the Act dated 03.10.2024 relating to A.Y.2021-22. 2 2. The grounds raised by the assessee read as under : 1) The order passed by the Ld. A.O./DRP is bad in law, illegal and non-est. 2) The Ld. TPO/DRP/A.O. has erred in not accepting the characterization of the assessee as software development provider

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., 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), 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., 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

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

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

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

144B of the Income Tax Act, 1961 2 Bilwa Infrastructure Limited vs. ITO (for short, “the Act”), dated 26/03/2024 for the Assessment Year (AY) 2018-19. The assessee company has assailed the impugned order of the CIT(A) on the following grounds of appeal: “1.The order of the Ld. CIT (A) u/s 250 of the Act dt. 20/06/2025

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

ACIT., CIRCLE-6(1), HYDERABAD vs. NEW CLUB, HYDERABAD

In the result, the appeal of the revenue is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TDS statement under section 194C that the assessee had received contract receipts of Rs.79,725/- during the relevant assessment year, which, in the absence of any documentary evidence, were treated as income from contract business and added to the total income of the assessee. The Ld. AO Page 3 of 12 New Club thereafter completed the assessment under section

SUKESINI KUMILI,HYDERABAD vs. ITO, WARD-15(1), HYDERABAD

TDS Statement Interest other than interest on securities (Section 194A) ANDHRA\nBANK, SITAPHALMANDI BR. 5 AMOUNT PAID OR CREDITED 31,890\n7.\n3. On the basis of above information, which reveals that the income chargeable to tax,\nrepresented in the form of asset, which has escaped assessment amount to the tune of\nRupees more than 50 lakhs, for the year

CH MARTHANDA RAO AND CO,HYDERABAD vs. ITO., WARD - 14(1), HYDERABAD

In the result, the order passed by the CIT(A) is modified in terms of our aforesaid observations, and the appeal filed by the assessee firm is allowed for statistical purposes in terms of our afore...

Bench: Us:

Section 147 r.w.s 144 r.w.s 144B of the Act, dated 23/03/2022 for the subject year i.e. 2014-15, taken cognizance of the submission of the successor company, viz. M/s Vensa Infrastructure Limited, that the partnership firm, i.e., M/s Ch. Marthanda Rao & Co. was converted into a limited company i.e. M/s CMR Projects Limited w.e.f 01/04/2012, and thereafter the company name

CH MARTHANDA RAO & CO,HYDERABAD vs. ITO, WARD - 14(1), HYDERABAD

In the result, the order passed by the CIT(A) is modified in terms of our aforesaid observations, and the appeal filed by the assessee firm is allowed for statistical purposes in terms of our afore...

Bench: Us:

Section 147 r.w.s 144 r.w.s 144B of the Act, dated 23/03/2022 for the subject year i.e. 2014-15, taken cognizance of the submission of the successor company, viz. M/s Vensa Infrastructure Limited, that the partnership firm, i.e., M/s Ch. Marthanda Rao & Co. was converted into a limited company i.e. M/s CMR Projects Limited w.e.f 01/04/2012, and thereafter the company name

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

TDS, without appreciating fact that, the payments are not taxable in India under the provisions of respective tax treaties. 7.2. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in not appreciating the fact that, by applying most favoured nation clause as contained in India Netherlands tax treaty and by accessing India-Finland