INCOME TAX OFFICER (INTERNATIONAL TAXATION), NELLORE vs. BADRI MANJULA , NELLORE

In the result, the appeal filed by the revenue is allowed and the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2009-10 Badri Hari Babu Vs. Ito(International 15/342, Subedarpet Taxation) Andra Pradesh Nellore Nellore-524 001

TDS is only a vicarious liability, which ceases to exist once the primary liability has been discharged” 11.1 during the course of the appeal proceedings, the appellant has produced the assessment order from ITO(IT) and also 26AS of the land seller. 11.2 By Finance Act, 2012, a proviso to Sub-section(1) was introduced whereby if it is proved

BADRI HARI BABU,NELLORE vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), HYDERABAD

In the result, the appeal filed by the revenue is allowed and the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2009-10 Badri Hari Babu Vs. Ito(International 15/342, Subedarpet Taxation) Andra Pradesh Nellore Nellore-524 001

TDS is only a vicarious liability, which ceases to exist once the primary liability has been discharged” 11.1 during the course of the appeal proceedings, the appellant has produced the assessment order from ITO(IT) and also 26AS of the land seller. 11.2 By Finance Act, 2012, a proviso to Sub-section(1) was introduced whereby if it is proved

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS credits, Advance Tax and Self Assessment Tax available in Form 26AS of KVR Rail Infra Projects Pvt Ltd should have been allowed to the assessee company. 4. The Ld. CIT(A) not appreciating the fact that the AO has inappropriately applied the provisions of section 234A

K & R RAIL ENGINEERING LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS credits, Advance Tax and Self Assessment Tax available in Form 26AS of KVR Rail Infra Projects Pvt Ltd should have been allowed to the assessee company. 4. The Ld. CIT(A) not appreciating the fact that the AO has inappropriately applied the provisions of section 234A

K & R RAIL ENGINEERING LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS credits, Advance Tax and Self Assessment Tax available in Form 26AS of KVR Rail Infra Projects Pvt Ltd should have been allowed to the assessee company. 4. The Ld. CIT(A) not appreciating the fact that the AO has inappropriately applied the provisions of section 234A

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS credits, Advance Tax and Self Assessment Tax available in Form 26AS of KVR Rail Infra Projects Pvt Ltd should have been allowed to the assessee company. 4. The Ld. CIT(A) not appreciating the fact that the AO has inappropriately applied the provisions of section 234A

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS credits, Advance Tax and Self Assessment Tax available in Form 26AS of KVR Rail Infra Projects Pvt Ltd should have been allowed to the assessee company. 4. The Ld. CIT(A) not appreciating the fact that the AO has inappropriately applied the provisions of section 234A

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

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

234A of the Act. 4) On the facts and circumstances of the case and in law, the Learned A.O. erred in charging interest u/s 234B of the Act. 5) On the facts and circumstances of the case and in law, the Learned A.O. erred in charging interest u/s 234C of the Act.” 3. The brief facts of the case

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

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

234A of the Act. 4) On the facts and circumstances of the case and in law, the Learned A.O. erred in charging interest u/s 234B of the Act. 5) On the facts and circumstances of the case and in law, the Learned A.O. erred in charging interest u/s 234C of the Act.” 3. The brief facts of the case

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. DIVI'S LABORATORIES LIMITED, HYDERABAD

In the result, appeal of the revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Asst. Commissioner Of Vs. Divi’S Laboratories Ltd., Income-Tax, Hyderabad. Central Circle – 2(1), Hyderabad. Pan – Aaacd 6745J (Appellant) (Respondent) Revenue By: Shri Anil S Assessee By: Shri S. Rama Rao Date Of Hearing: 20/07/2021 Date Of Pronouncement: 17/08/2021

234A) 11a 0 b For default in payment of advance tax (section 234B) 11b 0 c For deferment of advance tax (section 234C) 11c 0 d Total Interest Payable (11a+11b+11c) 11d 0 12 Aggregate liability (10 + 11d) 12 0 13 Taxes Paid a Advance Tax (from Schedule-IT) 13a 0 b TDS

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)

TDS payments, assets, borrowings, and other supporting documents. The assessee submitted partial and complete responses on various dates and also participated in video- conference proceedings on 12.09.2023, furnishing explanations on ICDS and related issues. Since the assessee had reported large 6 Gainsight Software Private Limited value international transactions in respect of provision of software development services, a reference was made

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

In the result, appeal filed by the assessee is allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.685/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2014-15) Sbpl Infrastructure Vs. Deputy Commissioner Limited Of Income Tax Hyderabad Circle-3(1) [Pan : Aaccs9014M] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Sashank Dundu, Ar रधजस् व द्वधरध/Revenue By: Shri M.Vijay Kumar,Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 04/12/2024 घोर्णध की तधरीख/Date Of 16/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)], National Faceless Appeal Centre (Nfac), Delhi Dated 13.02.2024 & Pertains To A.Y.2014-15. 2. This Appeal Filed By The Assessee Is Time Barred By 94 Days. The Assessee Filed A Petition For Condonation Of Delay & Submitted That Shri Manoj Sharma, Chief Financial Officer Of The Appellant Company, Who Was Entrusted With The Job Of Looking

section 234A,B & C. 11. For these and other grounds that may be urged at the time of hearing, appellant prays that the Hon’ble Tribunal may be pleased to delete the arbitrary additions made and upheld by the lower authorities. 5. The brief facts of the case are that the assessee company, engaged in the business of construction

INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE -2(1), HYDERABAD

Appeal is partly allowed in above terms

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

TDS ') amounting to Rs. 3,01,408 attributable to Infor (Bangalore) Private Limited and Rs. 3,49,350 attributable to Approva Systems Private Limited ('transferor companies') which were amalgamated with Appellant with effect from 01 April 2015. 18. On the facts and in the circumstances of the case and in law, the Ld AO erred in not granting credit

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

TDS of INR 2,389. :- 9 -: ITA Nos..227 & 228/Hyd/2021 ADP Pvt. Ltd., Hyd. 23. On the facts and circumstance of the case and in law, the ld. AO erred by granting credit of advance tax of INR 28,30,00,000 as against the eligible advance tax credit of INR 35,66,82,429 available to the Appellant. thereby

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

TDS of INR 2,389. :- 9 -: ITA Nos..227 & 228/Hyd/2021 ADP Pvt. Ltd., Hyd. 23. On the facts and circumstance of the case and in law, the ld. AO erred by granting credit of advance tax of INR 28,30,00,000 as against the eligible advance tax credit of INR 35,66,82,429 available to the Appellant. thereby

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 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