VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS) (2016) 178 ITJ 768 has held that Inter Connect Usage Charges (“IUC”) (which is similar to roaming charges) paid by assessee to foreign telecom operators was neither FTS nor royalty under the Act and DTAA. 3.5.16. Furthe, Hon’ble Delhi Tribunal following its own order in Bharti Airtel (supra) in case of Bharat Sanchar Nigam Ltd. vs. ACIT

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS) (2016) 178 ITJ 768 has held that Inter Connect Usage Charges (“IUC”) (which is similar to roaming charges) paid by assessee to foreign telecom operators was neither FTS nor royalty under the Act and DTAA. 3.5.16. Furthe, Hon’ble Delhi Tribunal following its own order in Bharti Airtel (supra) in case of Bharat Sanchar Nigam Ltd. vs. ACIT

VODAFONE IDEA LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS) (2016) 178 ITJ 768 has held that Inter Connect Usage Charges (“IUC”) (which is similar to roaming charges) paid by assessee to foreign telecom operators was neither FTS nor royalty under the Act and DTAA. 3.5.16. Furthe, Hon’ble Delhi Tribunal following its own order in Bharti Airtel (supra) in case of Bharat Sanchar Nigam Ltd. vs. ACIT

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS) (2016) 178 ITJ 768 has held that Inter Connect Usage Charges (“IUC”) (which is similar to roaming charges) paid by assessee to foreign telecom operators was neither FTS nor royalty under the Act and DTAA. 3.5.16. Furthe, Hon’ble Delhi Tribunal following its own order in Bharti Airtel (supra) in case of Bharat Sanchar Nigam Ltd. vs. ACIT

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS) (2016) 178 ITJ 768 has held that Inter Connect Usage Charges (“IUC”) (which is similar to roaming charges) paid by assessee to foreign telecom operators was neither FTS nor royalty under the Act and DTAA. 3.5.16. Furthe, Hon’ble Delhi Tribunal following its own order in Bharti Airtel (supra) in case of Bharat Sanchar Nigam Ltd. vs. ACIT

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS) (2016) 178 ITJ 768 has held that Inter Connect Usage Charges (“IUC”) (which is similar to roaming charges) paid by assessee to foreign telecom operators was neither FTS nor royalty under the Act and DTAA. 3.5.16. Furthe, Hon’ble Delhi Tribunal following its own order in Bharti Airtel (supra) in case of Bharat Sanchar Nigam Ltd. vs. ACIT

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

288/- by invoking provision of section 37(1) of the IT Act and therefore ought not to have upheld the addition to the extent of 50%. 7. The Hon'ble CIT(A) ought to have observed that in the facts and circumstances of the case, the action of the assessing officer in disallowing expenditure of Rs.19,50,548/-was improper

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

288/- by invoking provision of section 37(1) of the IT Act and therefore ought not to have upheld the addition to the extent of 50%. 7. The Hon'ble CIT(A) ought to have observed that in the facts and circumstances of the case, the action of the assessing officer in disallowing expenditure of Rs.19,50,548/-was improper

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

288/- by invoking provision of section 37(1) of the IT Act and therefore ought not to have upheld the addition to the extent of 50%. 7. The Hon'ble CIT(A) ought to have observed that in the facts and circumstances of the case, the action of the assessing officer in disallowing expenditure of Rs.19,50,548/-was improper

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

288/- by invoking provision of section 37(1) of the IT Act and therefore ought not to have upheld the addition to the extent of 50%. 7. The Hon'ble CIT(A) ought to have observed that in the facts and circumstances of the case, the action of the assessing officer in disallowing expenditure of Rs.19,50,548/-was improper

S A BUILDERS & DEVELOPERS ,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-1(2) , HYDERABAD

In the result, Ground Nos

section 153A is bad in law, the\nassessment has no leg to stand and the same is required to be\nquashed.\n10. Without prejudice to above legal contention the appellant\ncontends that following additions are liable to be deleted on\nmerits.\n(i)\nCreditors Appearing under Loans &\nAdvances (Asset)\nRs.1,44,86,500\nSl.No.\nName of the Customer\nClosing Balance

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(1) , HYDERABAD vs. S A BUILDERS AND DEVELOPERS , HYDERABAD

The appeals of the Revenue are dismissed

section 153A is bad in law, the\nassessment has no leg to stand and the same is required to be\nquashed.\n10. Without prejudice to above legal contention the appellant\ncontends that following additions are liable to be deleted on\nmerits.\n(i)\nCreditors Appearing under Loans &\nAdvances (Asset)\nRs.1,44,86,500\nSl.No.\nName of the Customer\nClosing Balance

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

TDS on the payments in question involving a canadian group entity as well as the ultimate recipient M/s. Soctronics India (P) Ltd. 4. Next come the impugned 271C proceedings taken recourse to by the learned lower authorities. A combined perusal of the instant case files suggests that the Assessing Officer had passed his all the penalty orders on 30.10.2015 after

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

TDS on the payments in question involving a canadian group entity as well as the ultimate recipient M/s. Soctronics India (P) Ltd. 4. Next come the impugned 271C proceedings taken recourse to by the learned lower authorities. A combined perusal of the instant case files suggests that the Assessing Officer had passed his all the penalty orders on 30.10.2015 after

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

TDS on the payments in question involving a canadian group entity as well as the ultimate recipient M/s. Soctronics India (P) Ltd. 4. Next come the impugned 271C proceedings taken recourse to by the learned lower authorities. A combined perusal of the instant case files suggests that the Assessing Officer had passed his all the penalty orders on 30.10.2015 after

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

TDS on the payments in question involving a canadian group entity as well as the ultimate recipient M/s. Soctronics India (P) Ltd. 4. Next come the impugned 271C proceedings taken recourse to by the learned lower authorities. A combined perusal of the instant case files suggests that the Assessing Officer had passed his all the penalty orders on 30.10.2015 after

RK INFRA & ENGINEERING INDIA PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-3, HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2015-16 R.K. Infra & Engineering India Vs. Income Tax Officer, Private Limited, Ward – 3, Hyderabad. Hyderabad. Pan : Aadcr9570Q (Appellant) (Respondent) Assessee By: Shri Pawan Kumar Chakrapani Revenue By: Shri Jeevan Lal Lavidiya Date Of Hearing: 21.11.2022 Date Of Pronouncement: 22.11.2022

TDS details and other related documents were produced for verification before the learned assessing officer, the assessing officer had verified all the documents produced and having satisfied had accepted the income of the Appellant as NIL. 8.13 It is also relevant to bring to the notice of this Hon'ble Tribunal that for the purpose of invoking the provisions

RAIN CEMENTS LIMITED, HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2008-09 M/S. Rain Cements Ltd Vs. Dy. Commissioner Of (Formerly Known As Rain Income Tax, Circle 3 (1) Cii Carbon (India) Ltd Hyderabad Hyderabad Pan:Aabcr8858F (Appellant) (Respondent) Assessee By: Advocate Prathishta Singh & Advocate Deepak Chopra Revenue By: Dr.Rajendra Kumar, Cit-Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 24.03.2017 Passed U/S 143(3) R.W.S. 144C(5) R.W.S. 260 Of The I.T. Act For The A.Y 2008-09. 2. This Appeal Was Earlier Decided By The Tribunal Vide Order Dated 18.10.2019. Subsequently Vide Ma No.15/Hyd/2020, Dated 23.3.2021, The Tribunal Recalled The Entire Order For Fresh Adjudication. Therefore, This Is A Recalled Matter.

TDS to an extent of Rs. 9,70.814/- 15. The Ld. AO erred in computing interest u/s 234B of Rs. 31,16.646/- 16. The Ld. AO erred in computing interest u/s 234C of Rs. 37,20,130/-. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter