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

TDS) under Section 194C of the Act of Rs.\n1,36,78,178/- on the contract payments of only Rs.\n82,64,73,583/-. The Pr. CIT, based on the aforesaid facts, held a\nfirm conviction that as the “Faceless Assessing Officer” (for short,\n“FAO”) had, while framing the assessment not verified the reason\nfor non-deduction

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 under section 194C of the Act. Although, the Assessing Officer has made 10% ad-hoc disallowance of expenditure debited under the Head “Rents/JCB/Tipper/ Crane”, but, in our considered view, the said disallowance was made on the basis of directions of the learned PCIT in the order passed under section 263

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

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

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

TDS on ESOP is an international transaction with its AE which was not at arm's length. 4:2 The Appellant submits that considering the facts and circumstances of its case and the law prevailing on the subject the international transactions relating to recovery of expenses were at arm's length and hence no adjustment in respect thereof was called

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

TDS on ESOP is an international transaction with its AE which was not at arm's length. 4:2 The Appellant submits that considering the facts and circumstances of its case and the law prevailing on the subject the international transactions relating to recovery of expenses were at arm's length and hence no adjustment in respect thereof was called

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

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

BBR PROJECTS LIMITED,,HYDERABAD vs. ITO WARD-1(4), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 M/S.Bbr Projects Private Vs. The Income Tax Officer, Limited, Ward – 1(14), Hyderabad. Hyderabad. Pan : Aaccb7153J (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Vijay Bhaskar Reddy – Cit-Dr Date Of Hearing: 21.09.2022 Date Of Pronouncement: 11.10.2022

section 263 of the Income Tax Act, 1961 (in short, “the Act”) wherein the order passed by Assessing Officer on 24.12.2019 was set aside. 2 2. The grounds raised by the assessee reads as under : “1. The order u/s 263 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') passed by the Ld.Pr. Commissioner of Income

LYCOS INTERNET LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

263 of the I.T Act, 1961 and the assessing officer is directed to examine the above discrepancies and assess the correct income by redoing the assessment afresh after affording an opportunity of being heard to the assessee. The assessment order dated 29 03 2016 stands revised accordingly”.\n\n18.\nThus,, the order of the Assessing Officer was set aside/revised

HRITIK EXIM,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-10(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Hritik Exim Vs. Dcit, Circle-10(1) C/O P.Murali & Co. 5Th Floor, It Towers Chartered Accountants Ac Guards 6-3-655/2/3 Hyderabad-500 004 Somajiguda Hyderabad-500 082

TDS, the same has been accounted for and therefore, the ld.PCIT was not justified in invoking the provisions of section 263

PROGRESSIVE CONSTRUCTIONS LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.625/Hyd/2025 Assessment Year 2021-2022 Progressive Constructions The Dcit, Limited, Hyderabad. Circle-5(1) Vs. Pin – 500 001. Telangana. Hyderabad - 500 004. Pan Aabcp2274M Telangana. (Appellant) (Respondent) Ca Pawan Kumar Chakrapani िनधा"रती "ारा/Assessee By : & Sri Santi Pavan Kumar, Advocate राज" व "ारा/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 02.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

section 263 of the Act, under the facts and circumstances of the case. 7. The Honorable Pr. CIT ought to have appreciated the fact that, the claim of bad debts are allowable as the amount of Rs.141,66,01,735/-, is taken into account in computing the income of the Appellant of the previous years, under the facts and circumstances

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

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

Section 263 of the Act\nwas passed in assessee's case on 13.03.2020 by the learned PCIT\nand set aside the order of the A.O. to verify the issues discussed in\n263 proceedings like the claim of interest on TDS

UNITED RAIL ROAD CONSULTANTS PRIVATE LIMITED (UNIQUE RAIL ROAD CONSULTANTS PVT LTD NOW MERGED WITH UNITED RAIL ROAD CONSULTANTS PVT LTD ,HYDERABAD vs. DCIT-1 CENTRAL CIRCLE-1(3), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2015-16 M/S. United Rail Road Vs. Dy. C.I.T Consultants (P) Ltd., Central Circle 1(3) Secunderabad Hyderabad Pan:Aaacu8136E (Appellant) (Respondent) Assessee By: Shri M.V. Joshi, C.A Appeared For Shri P. Murali Mohan Rao, Ca Revenue By: Shri Jeeval Lal Lavidiya, Dr Date Of Hearing: 12/01/2023 Date Of Pronouncement: 30/01/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.3.2020 Passed U/S 263 Of The I.T. Act, 1961 By The Learned Pr.Cit (Central)- Hyderabad, Relating To A.Y.2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Company Was Engaged In The Business Of Providing Consultancy Services. It Filed Its Return Of Income For The A.Y 2015-16 On 29.9.2015 Declaring Total Income Of Rs.2,29,74,860/-. The Case Was Selected For Scrutiny Through Cass In The Limited Scrutiny To Verify “Large Other Expenses Claimed In The Profit & Loss A/C & Mismatch In Sales Turnover Reported In Audit Report &

section 199, it was submitted that once the TDS was deducted, a credit to the same has to be given to the assessee irrespective of the year to which it relates. Relying on various decisions, it was argued that the initiation of 263

MECH ENGINEERS AND ERECTORS PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -2(1), HYDERABAD

Appeals are allowed in above terms

Bench: Shri A.Mohan Alankamony & Shri S.S.Godara

Section 263 revision orders in issue that on account of the assessee having not deducted TDS, audit fee and difference