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

6. That the facts and circumstances of the case, DRP is not justified in confirming the ALP of fly ash at Rs. 65.76/- per ton, determined without considering the freight component s part of landed cost of fly-ash, and making an adjustment of Rs. 60,90,830/-. 7. That in the facts and circumstances of the case

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.:

6 of 20 ITA No 670 of 2023 Nippon Koei Co Ltd invoices to the assessee for the consultancy services rendered. Such invoicing would never arise in the case of an employer- employee relationship. The payments were in the nature of professional fees and were not salary payments. Hence, TDS was not deductible under section

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

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

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

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

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)

6 ADP Private Limited The Ld. TPO and the Hon'ble DRP erred in not undertaking objective comparative analysis and interalia rejecting Orangescape Technologies Private Limited as comparable company. 9. Ground 9: Not considering certain companies which are functionally comparable to the Assessee The Hon'ble DRP erred in upholding/confirming the actions of the Ld. TPO in rejecting the additional

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

270A of the Act, the primary condition is to prove ‘mens rea’, i.e., guilty mind or an act of conscious concealment or furnishing of inaccurate particulars on part of Assessee, whereas the Appellant has disclosed all the information requested ITA No.785/Hyd/2024 6 for during the assessment proceedings as well as at the time of filing the Income tax return. (6

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

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

6. CA, G Srinivasa Rao, Learned Counsel for the Assessee submitted that, the learned CIT(A) was erred in not allowing deduction claimed by the appellant u/sec.43B of the Act to the extent of Rs.1,66,44,340/- towards TDS 10 ITA.Nos.736 & 743/Hyd./2025 payments pertaining to assessment year 2017-2018, even though, the assessee has filed relevant challans

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

6. CA, G Srinivasa Rao, Learned Counsel for the Assessee submitted that, the learned CIT(A) was erred in not allowing deduction claimed by the appellant u/sec.43B of the Act to the extent of Rs.1,66,44,340/- towards TDS 10 ITA.Nos.736 & 743/Hyd./2025 payments pertaining to assessment year 2017-2018, even though, the assessee has filed relevant challans

SHELADIA ASSOCIATES INC,SECUNDERABAD vs. ADIT (INT TAXN)-2, HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1401/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2022-23) Sheladia Associates Inc. Vs. Adit (International Secunderabad Taxation)-2 Pan : Aafcs7792F Hyderabad

6. The AO has erred in initiating penalty proceedings u/s 270A of the Act. 7. Any other grounds that may be urged at the time of hearing. 3. Ground No.1 and 2 are general in nature and does not require any specific adjudication. Even the assessee has not brought anything in support of these grounds to show that the order

KARVY INSIGHTS LIMITED,HYDERABAD vs. DCIT, CIRCLE 2(1), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year – 2020-21 Karvey Insights Limited, Vs. The Deputy Commissioner Of Income Tax, Karvy House, Circle – 2(1), Hyderabad. Hyderabad. Pan : Aafck7501C (Appellant) (Respondent) Assessee By: Shri H. Srinivasulu, Advocate. (Appeared Through Virtual Hearing) Revenue By: Ms. Th Vijaya Lakshmi, Cit-Dr. Date Of Hearing: 03.09.2024 Date Of Pronouncement: 04.09.2024

6. Ld. CIT (A), ought not have confirmed the addition of Rs. 10,64,04,646 by the Ld. AO, without going adequate opportunity. Ld. CIT(A) erred in disallowing a sum of Rs.10,64,04,646/- which was incurred wholly and Exclusively for the purpose of business and is completely supported by the Evidence. 3. Facts of the case

BHARGAVI MARKETERS,HYDERABAD vs. ITO., WARD 6(1), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2016-17 Bhargavi Marketers, Vs. The Income Tax Officer, Ward – 6(1), Hyderabad. Hyderabad. Pan : Aapfb3209D (Appellant) (Respondent) Assessee By: Shri V. Venkata Rao, C.A. Revenue By: Ms. Kavitha Rani, Sr.A.R. Date Of Hearing: 04.12.2024 Date Of Pronouncement: 05.12.2024

6(1), Hyderabad. Hyderabad. PAN : AAPFB3209D (Appellant) (Respondent) Assessee by: Shri V. Venkata Rao, C.A. Revenue by: Ms. Kavitha Rani, Sr.A.R. Date of hearing: 04.12.2024 Date of pronouncement: 05.12.2024 O R D E R PER LALIET KUMAR, J.M: This appeal is filed by the assessee feeling aggrieved by the order passed by the Commissioner of Income Tax (Appeals), National Faceless