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

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

TDS credit amounting to INR 6,360 appearing in the Form 26AS as per the\nOGE dated 07 February 2024 pursuant to the order of Hon'ble CIT(A).\n19. erred in levying interest under section 234C of the Act in the impugned order.\n20. erred in initiating penalty proceedings under section 270A of the Act against the Appellant without

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

144C(5) of the Act and read with order dated 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

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

144C(5) of the Act and read with order dated 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

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

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

Bench: Us :

Section 143(3) r.w.s. 144C(3) of the Income Tax Act, 1961, (for short “the Act”) dated 24-05-2024. The Revenue has assailed the impugned order on the following grounds of appeal before us : “1. The Ld. CIT(Appeals) erred both in law and on facts of the case in setting aside the assessment order passed by the Assessing

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

144C of the Act. 33.5 Moreover, the disallowance of gratuity expenses was factually and legally flawed. Section 43B allows deduction for gratuity expenses paid before the due date of filing return under section 139(1) of the Act. The assessee has provided evidence that the payment was made on 15th September 2020, i.e., before the due date, and the same

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

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.:

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

PRAKASH KANYADARA,VIJAYAWADA vs. INCOME TAX OFFICER (INT TAXN)-1, HYDERABAD

In the result, appeal of the assessee is treated as allowed for statistical purposes

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

TDS was deducted, that he duly declared this income in the return of income filed on 25/10/2021 in response to notice issued under section 148 dated 24/06/2021 admitting total income of Rs. 3,68,920/-. Assessee further submitted that the cash deposits made into the bank account are out of cash in hand brought forward from preceding previous years

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

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

TDS Rs. 26165215 Less : Advance Tax Rs. 12000000 Balance Tax Rs. 32835948 Add: Interest u/s 234A Rs. 1970157 Add: Interest u/s 234B Rs. 10835863 Add: Interest u/s 234C Rs. 0 Total tax + Int payable Rs. 45641967 Less: Self tax paid Rs. Less: Regular by Rs. 29414128 adjustment of refund Balance Payable. Rs. 16227839 Madhucon Projects Limited, Hyderabad. 25. The assessee

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

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

TDS Rs. 26165215 Less : Advance Tax Rs. 12000000 Balance Tax Rs. 32835948 Add: Interest u/s 234A Rs. 1970157 Add: Interest u/s 234B Rs. 10835863 Add: Interest u/s 234C Rs. 0 Total tax + Int payable Rs. 45641967 Less: Self tax paid Rs. Less: Regular by Rs. 29414128 adjustment of refund Balance Payable. Rs. 16227839 Madhucon Projects Limited, Hyderabad. 25. The assessee

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

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

TDS Rs. 26165215 Less : Advance Tax Rs. 12000000 Balance Tax Rs. 32835948 Add: Interest u/s 234A Rs. 1970157 Add: Interest u/s 234B Rs. 10835863 Add: Interest u/s 234C Rs. 0 Total tax + Int payable Rs. 45641967 Less: Self tax paid Rs. Less: Regular by Rs. 29414128 adjustment of refund Balance Payable. Rs. 16227839 Madhucon Projects Limited, Hyderabad. 25. The assessee

KNR CONSTRUCTIONS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

144C(13)\nof the Act on 29.07.2022, making an addition of\nRs.36,77,04,171/-, thereby determining the total assessed income\nof the assessee at Rs.94,76,61,851/-.\n4. Aggrieved with the order of the Ld. AO, the assessee is\nin appeal before this Tribunal. At the outset, the Learned\nAuthorized Representative (“Ld. AR”) submitted that the solitary\nissue

ALBANY MOLECULAR RESEARCH HYDERABAD RESEARCH CENTER PVT..LTD., HYD,R.R.DIST vs. DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD

Accordingly, the ground No.1 raised by the revenue is dismissed

Bench: Shri C.N. Prasad, Jm & Shri M.Balaganesh, Am

144C(5) of the Income Tax Act, 1961 (in short „the Act‟). Stay Application Nos. 51/Hyd/2020 is arising out of 107/Hyd/2016) for A.Y. 2012-13 & SA No.52/Hyd/2020 is arising out of ITA No. 2376/Hyd/2018 for A.Y.2014-15. The identical issue is involved in all these assessee appeals and hence they are taken up together and disposed off by this common order

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

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute Resolution

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

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute Resolution