BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 40(a)(ia) of the Act. 39. In respect of machinery hire charges of Rs. 16,88,379/-, the assessee claims that, it has deducted TDS of Rs. 1,28

P AMRUTHA PRASAD ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections

P AMRUTH PRASAD,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections

SRINIVAS UPPU ,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD vs. AMRUT PRASAD PATNAM , HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections

SRINIVAS UPPU,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is partly allowed

28. Therefore, Section 145(1) is attracted to the facts of the present case. Under the mercantile system of accounting, what is due is brought into credit before it is actually received; it brings into debit an expenditure for which a legal liability has been incurred before it is actually disbursed. (see judgment of this Court in the case

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

Section 143(3) r.w.s. 263 r.w.s.\n144B of the Income-tax Act, 1961, on 24.09.2021 and determined\nthe total income at Rs. 28,46,91,790/- by making additions of Rs.\n8,77,278/- towards disallowance of interest on TDS

NALGONDA REALTORS PRIVATE LIMITED ,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

28. The assessee carried the matter in appeal before the ld.CIT(A). The ld.CIT(A) for the reasons stated in their order dated 18-09-2020 partly allowed the appeal filed by the assessee where the ld.CIT(A) sustained additions made towards disallowance of fiancé charges to Rs.76,24,876/- out of total addition made by the Assessing Officer

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

28. The assessee carried the matter in appeal before the ld.CIT(A). The ld.CIT(A) for the reasons stated in their order dated 18-09-2020 partly allowed the appeal filed by the assessee where the ld.CIT(A) sustained additions made towards disallowance of fiancé charges to Rs.76,24,876/- out of total addition made by the Assessing Officer

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

28. The assessee carried the matter in appeal before the ld.CIT(A). The ld.CIT(A) for the reasons stated in their order dated 18-09-2020 partly allowed the appeal filed by the assessee where the ld.CIT(A) sustained additions made towards disallowance of fiancé charges to Rs.76,24,876/- out of total addition made by the Assessing Officer

CYIENT LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2021-22 Cyient Limited, Vs. The Deputy Commissioner Of Income Tax, Circle 1 (1), Hyderabad. Hyderabad. Apn : Aaac14887J

28,52,83,944/- and made addition of Rs.38,55,85,183/- u/s 40(a)(ia) of the Act. 13. The assessee filed objections against draft assessment order before the Dispute Resolution Panel – 1, Bangalore and filed certain additional evidences, including details of salaries paid without TDS, employees names, addresses and their PAN numbers and also explained that

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE -1(2) , HYDERABAD vs. AMSRI INFRA PROJECTS PRIVATE LIMITED, SECUNDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

section 28(iv)? vi) Whether in facts and circumstances, the CIT(A) failed to appreciate that whether a receipt of money is taxable or not or whether certain deductions from that receipts are permissible in law or not, the question has to be decided according to the principles of law and not in accordance with accountancy practice. vii) Whether

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE -1(2) , HYDERABAD vs. AMSRI BUILDERS PRIVATE LIMITED, SECUNDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

section 28(iv)? vi) Whether in facts and circumstances, the CIT(A) failed to appreciate that whether a receipt of money is taxable or not or whether certain deductions from that receipts are permissible in law or not, the question has to be decided according to the principles of law and not in accordance with accountancy practice. vii) Whether

AMSRI INFRA PROJECTS PRIVATE LIMITED,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

section 28(iv)? vi) Whether in facts and circumstances, the CIT(A) failed to appreciate that whether a receipt of money is taxable or not or whether certain deductions from that receipts are permissible in law or not, the question has to be decided according to the principles of law and not in accordance with accountancy practice. vii) Whether

AMSRI BUILDERS PRIVATE LIMITED,SECUNDRABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

section 28(iv)? vi) Whether in facts and circumstances, the CIT(A) failed to appreciate that whether a receipt of money is taxable or not or whether certain deductions from that receipts are permissible in law or not, the question has to be decided according to the principles of law and not in accordance with accountancy practice. vii) Whether

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

TDS credits. Hence, the addition of Rs. 92,069/-is sustained. 5.4. The appellant has raised several grounds 5.4. The against the addition of Unexplained Investment u/s 69B at Rs.19,54,348/- The AO made an addition of Rs. 19,54,348/- as unexplained time deposits since no source was explained during the assessment proceedings. The appellant contends that these

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

TDS short credit. 4. In so far as the issue relating to the disallowance of deduction claimed under section 80G of the Act qua expenditure incurred in Corporate Social Responsibility ("CSR") is concerned, plea of the assessee is that the assessee donated/ contributed Rs. 3,79,83,500/- towards CSR during the financial year 2016-17 which was debited