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.:

2 of the assessee is dismissed. 13. The Ground No.3 of the assessee pertains to the addition of Rs.3,49,255/- made by the Ld. AO on account of disallowance of certain expenses under section 44DA of the Act. It was submitted that these expenses represent small amounts incurred towards reimbursement of expenses incurred by the staff of the Head

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

TDS to the tune of Rs. 30,211/- without assigning any reasons therefor. 10. The appellant craves leave to add, amend or alter any of the grounds during the course of hearing.” 2. Brief facts of the case are that the assessee-company is engaged in manufacturing of Clinker and Ordinary Portland Cement. The assessee, being the third largest cement

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)

2) of the Income-tax Act, 1961 dated 29.06.2021 was issued and served upon the assessee. Subsequently, the case was transferred to the Regional e-Assessment Centre under the Faceless Assessment Scheme, 2019. During the assessment proceedings, several notices under Section 142(1) of the Act were issued on 29.09.2022, 04.01.2023, 19.01.2023, and 28.07.2023, calling for details relating to business

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)

2) of the Act. (b) Not appreciating the submissions made by the Appellant that the payments made to recipient/s are not chargeable to tax in India and accordingly, taxes were not liable to be deducted on the same and have erred in concluding that the Appellant is required to deduct TDS on payment for business support service expenses

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

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)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

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)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

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)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

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)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

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)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

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)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

KAKINADA INFRASTRUCTURE HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

270A of the Act and, therefore, the reasons explained\nby the assessee are factually not disputed because the\ndecision to file the appeal has been taken only after the\npenalty order passed by the Assessing Officer. The Assessee\nhas explained the reasons for delay that only after the levy of\npenalty, the assessee has an imminent risk of facing

TPL- SUCG CONSORTIUM ,HYDERABAD vs. INCOME TAX OFFICER, CIRCLE 6(3), HYDERABAD

In the result, the appeal of assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

2) of the Act was issued on 22.09.2019 and thereafter, e-notices u/s 142(1) of the Act were issued on various dates calling for certain details. During assessment proceedings, the AO noted that the deduction claimed by the appellant u/s 80IA included retention money of Rs.31,86,76,819/-. The AO held that since the retention money withheld

DAICEL CHIRAL TECHNOLOGIES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2017-18 M/S. Daicel Chiral Vs. 1. Deputy Technologies India Private Commissioner Of Limited, Income Tax, Circle Medchal, 8(1), Hyderabad. Hyderabad. 2. National Faceless Pan : Aaccd8423B. Assessment Centre, Delhi. (Appellant) (Respondent) Assessee By: Shri N. Pradeep Revenue By: Shri T. Vijaya Bhaskar Reddy Date Of Hearing: 01.02.2023 Date Of Pronouncement: 03.02.2023 O R D E R Per Laliet Kumar, J.M.

2(24) of the Act reads which section 4 and 10 of the Act is that given its ordinary and natural meaning. The word income we take in any monetary return come in. The work income is of the widest amplitude and must be given its natural and grammatical meaning —CIT v G R Karthikeyan

ASWARTHANARAYANA VENKATA RENIGUNTLA,DHARMAVARAM vs. ITO, WARD-1, ANANTAPUR

In the result, the appeal of the assessee allowed

Bench: Shri Laliet Kumarassessment Year: 2017-18 Shri Aswarthanarayana Venkata Vs. Ito, Ward-1, Anantapur. Reniguntla, Dharmavaram, Andhra Pradesh. Pan : Alrpr5400R (Appellant) (Respondent) Assessee By: Sri M. Chandramouleswara Rao, Ca Revenue By: Sri A. Sitarama Rao. Date Of Hearing: 11.04.2023 Date Of Pronouncement: 11.04.2023

270A and 271F will be initiated separately. The contentions of the ld. AR are that : 1) No satisfaction has been recorded by the Assessing Officer in the assessment order and therefore, penalty order cannot be passed u/s 271B of the Act. 2) Assessee had filed Audit Report during the assessment proceedings and the Assessing Officer had satisfied and hence, there

SDS METALS (I) PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-3(1), HYDERABAD

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

Bench: Shri Laliet Kumarassessment Year: 2017-18 Sds Metals (I) Private Vs. The Income Tax Officer, Limited, Hyderabad. Ward –3(1), C/O. P. Murali & Co., Hyderabad. Chartered Accountants, 6-3-655/2/3, Somajiguda, Telangana – 500082. Pan : Aascs1826P. (Appellant) (Respondent) Assessee By: Shri P. Murali Krishna, C.A. Revenue By: Shri B. Yadagiri, Sr.Ar Date Of Hearing: 07.03.2024 Date Of Pronouncement: 07.03.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2017-18 Arises From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dt.18.09.2023 Invoking Proceedings Under Section 143(3) Of The Income Tax Act, 1961 (In Short, “The Act”).

section 143(3) of the Income Tax Act, 1961 (in short, “the Act”). 2. The appeal filed by the assessee is barred by limitation by 77 days. He has moved a condonation application explaining reasons thereof. I have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, I allow the application

ORBIS REAL ESTATE FUND I,HYDERABAD (AUTH. REP.) vs. ADIT (INTERNATIONAL TAXATION)-2 - 2, HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

2) The Ld. AO failed to recognize genuineness of substance of full time functioning advisory firm in Mauritius and board of directors meeting wholly held in Mauritius and he/she has erred in applying the applicable provisions of the India-Mauritius Double tax avoidance agreement (“DTAA”). (3) The Ld. AO erred in recharacterizing the nature of transaction from sale of shares

KALBURGI CEMENT PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

270A of 3 the Act. Thereafter, final assessment order was passed u/s 143(3) r.w.s. 144C(4) read with section 144B of the Act dt.23.11.2011. 2.1. Being aggrieved by the order dt.23.11.2011, assessee company filed an application u/s 263 of the Act before the PCIT – 2, Hyderabad, seeking revision of the assessment order dt.23.11.2011 passed by the National Faceless Assessment

MAGNAQUEST TECHNOLOGIES LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, ITA.No.736/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 270A under which the penalty proceedings are initiated in the appellant case and hence the penalty order passed by AO u/s 270A is liable to be quashed. 3. That on the facts and circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi has erred in not appreciating