SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

155 or sub-section (4) of section 186 no amendment under this section shall be made after the expiry of four years from the end of the financial year in which the order sought to be amended was passed.” The appellant has filed the rectification application on 05/12/2022 i.e. after the expiry of four years from

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

155 or sub-section (4) of section 186 no amendment under this section shall be made after the expiry of four years from the end of the financial year in which the order sought to be amended was passed.” The appellant has filed the rectification application on 05/12/2022 i.e. after the expiry of four years from

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

155 or sub-section (4) of section 186 no amendment under this section shall be made after the expiry of four years from the end of the financial year in which the order sought to be amended was passed.” The appellant has filed the rectification application on 05/12/2022 i.e. after the expiry of four years from

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD(TDS)-2(2),, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

155 or sub-section (4) of section 186 no amendment under this section shall be made after the expiry of four years from the end of the financial year in which the order sought to be amended was passed.” The appellant has filed the rectification application on 05/12/2022 i.e. after the expiry of four years from

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

155 or sub-section (4) of section 186 no amendment under this section shall be made after the expiry of four years from the end of the financial year in which the order sought to be amended was passed.” The appellant has filed the rectification application on 05/12/2022 i.e. after the expiry of four years from

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

155 or sub-section (4) of section 186 no amendment under this section shall be made after the expiry of four years from the end of the financial year in which the order sought to be amended was passed.” The appellant has filed the rectification application on 05/12/2022 i.e. after the expiry of four years from

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 credits without offering the corresponding income to tax by not taking cognizance of the submissions made by the Appellant explaining that such income would have been offered to tax either in the current year or in earlier years or in the subsequent years, depending upon the revenue recognized in the books of accounts on an accrual basis

VIRUPAKSHA ORGANICS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

Appeal is allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 40(a)(i) disallowance of Rs.16,61,611/- claimed towards foreign sales commission without deducting TDS thereupon. :- 2 -: 3. We noted that the Assessing Officer’s assessment order dt.29-12-2017 taken into consideration the assessee’s alleged agreement to the impugned disallowance as upheld in the CIT(A)’s order. The very factual position continues before us as well

SKANDA BUILDERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

TDS provisions\nand the question of disallowance u/sec.40(a)(ia) of the Income\nTax Act, 1961 [in short “the Act”], but, failed to give any\nspecific example of any expenditure which can be subjected to\nprovisions of sec.40(a)(ia) of the Act and also the decision of\njurisdictional High Court in the case of Indwell Construction

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:

155 32 ITA.No.1330/Hyd./2025 taxmann.com 580 (Calcutta), wherein Hon'ble Court has held as under:- “The assessee has placed Instruction issued by the CBDT dated 30-11-2017, being F. No. DGIT(Vig)/HQ/S1/2017- 18, wherein the CBDT has noted instances where some of the Assessing Officer were travelling beyond the issues while making assessment in limited scrutiny cases

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

TDS credit as per law. The above ground is allowed to that extent accordingly. The Ground nos. 6 & 7 are consequential to the grounds adjudicated above, therefore needs no separate adjudication. To sum up the appeal is partly allowed.” 5. Feeling aggrieved by the order passed by the ld.CIT(A), the Revenue is now in appeal before

ACIT, CENTRAL CIRCLE - 2(2), HYDERABAD vs. AMR INDIA LIMITED, HYDERABAD

In the result, Cross Objection No

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

sections 147/148 of the Act and those powers are saved. 13 ITA.Nos.534 & 535/Hyd./2024 & C.O.Nos.4 & 5/Hyd./2025 The question involved in the present set of appeals and review petition is answered accordingly in terms of the above and the appeals and review petition preferred by the Revenue are hereby dismissed. No costs." 6.3.1. Applying the judgment

ACIT, CENTRAL CIRCLE - 2(2), HYDERABAD vs. AMR INDIA LIMITED, HYDERABAD

In the result, Cross Objection No

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

sections 147/148 of the Act and those powers are saved. 13 ITA.Nos.534 & 535/Hyd./2024 & C.O.Nos.4 & 5/Hyd./2025 The question involved in the present set of appeals and review petition is answered accordingly in terms of the above and the appeals and review petition preferred by the Revenue are hereby dismissed. No costs." 6.3.1. Applying the judgment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. MAGNA HOMES, HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2018-19 The Deputy Commissioner Of Vs. M/S. Magna Homes, Hyderabad. Income Tax, Central Circle 3(1), Pan : Aapfg5917K Hyderabad. (Appellant) (Respondent) Assessee By: Shri Ravi Bharadwaj Revenue By: Dr. Sachin Kumar, Sr.D.R. Date Of Hearing: 08.01.2025 11.02.2025 Date Of Pronouncement:

section 148A(b) was issued to the appellant on 16.03.2022 and in response, the appellant has 3 ITA 327/Hyd/2024 not furnished any information. Order u/s. 148A(d) was passed with the prior approval of the specified authority. Accordingly, notice u/s. 148 of the Act was issued to the appellant on 30.03.2022. However, the appellant has not filed any return