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

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

3) r.w.s 147 of the IT Act for the A.Y 2010-11. Respectfully following the above decisions (cited supra), we hold that the assessee, which is following a uniform and consistence method of accounting, and has claimed the expenditure in accordance with the notification of the Min of Corporate Affairs and the A.O has allowed the same in the subsequent

SKANDHANSHI DEVELOPERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

TDS, which attracts disallowance u/sec.40(a)(ia) of the Income Tax Act, 1961. Therefore, considering the overall scenario including relevant books of accounts maintained by the assessee and incriminating material found during the course of search observed that, the profit percentage of undisclosed turnover found during the course of search proceedings should be more than the profit percentage

RAMKY INFRASTRUCTURE LIMITED, HYDERABAD,HYDERABAD vs. JCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2009-10 Ramky Infrastructure Ltd, Vs. Joint Commissioner Of Hyderabad. Income Tax, Pan:Aaacr8627B Circle 3(1), Hyderabad. (Appellant) (Respondent) Assessee By: Shri A.V. Raghuram. Revenue By: Shri Jeevan Lal Lavidiya, Dr Date Of Hearing: 15/11/2022 Date Of Pronouncement: 28/11/2022 O R D E R Per Laliet Kumar, J.M

TDS as per the relevant provisions of the Act. 7. Any other ground or grounds as may be urged at the time of hearing”. 3. The learned Counsel for the assessee submitted the following written submissions: “1. In the present case, the AO passed assessment orders for asst. years 2003-04 to 2009-10 on various dates denying the benefit

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

3. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price ("ALP") in respect of Marketing support services paid to M/s 000 Dr. Reddy's Laboratories Limited, Russia, by i. Rejecting the TNMM as most appropriate method and aggregation approach adopted by the Appellant. ii. violating the provisions

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

3. That on the facts and circumstances of the case and in law, the TPO/AO/DRP erred in determination of Arm's Length Price ("ALP") in respect of Marketing support services paid to M/s 000 Dr. Reddy's Laboratories Limited, Russia, by i. Rejecting the TNMM as most appropriate method and aggregation approach adopted by the Appellant. ii. violating the provisions

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.917/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2020-21) Shakti Hormann Private Limited, Hyderabad. Vs. Dcit, Circle-3(1), Hyderabad. Pan: Aadcs4024Q (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 15/10/2025 घोषणा की तारीख / Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Final Assessment Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The

3. During the course of the assessment proceedings, the AO for benchmarking the international transactions of the assessee company referred the matter to the Transfer Pricing Officer (TPO) on 16/01/2022 under section 92CA of the Act. 4. The assessee furnished information before the TPO, who after necessary deliberations, passed an order under section 92CA of the Act, dated 30/07/2023, proposing

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS without remittance and also cooperated in all the assessment proceedings. 3. The CIT (Appeals) is not justified in supporting the assessing officer who acted against law in imposing the penalty on the assessee under section

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS without remittance and also cooperated in all the assessment proceedings. 3. The CIT (Appeals) is not justified in supporting the assessing officer who acted against law in imposing the penalty on the assessee under section

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS without remittance and also cooperated in all the assessment proceedings. 3. The CIT (Appeals) is not justified in supporting the assessing officer who acted against law in imposing the penalty on the assessee under section

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

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

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

section 143(3) r.w.s. 144C(13) r.w.s. 1448 of the Income tax Act, 1961 ("the Act"), for the aforesaid assessment year on the following among other grounds 1:0 Transfer Pricing Adjustment of INR 16,86,23,336/- to the international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

TDS, or self-assessment tax discrepancies. 25.1 The taxpayer is notified of any adjustments via an intimation under section 143(1) of the Act, and they are given an opportunity to respond before any demand is raised. 25.2 However, an intimation under Section 143(1) is not an assessment. It is merely a preliminary check of the return filed

SKANDHANSHI DEVELOPERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

section 145(3) of the I.Act. The books of accounts maintained by the assessee are therefore rejected.\n\nThe relevant findings of the Assessing Officer are as follows :\n\nThe assessee is not in a position to substantiate its claim of expenses by producing supporting vouchers and other documentary evidences to establish the admissibility of expenses associated with the undisclosed

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted the provisions of section 40(a)(ia) of the Act; and (ii) and though the assessee company had during the subject year carried out international transactions with its Associated Enterprises (AEs) of Rs.23,97,35,320/-, but the AO in the course

ITO (INTERNATIONAL TAXATION)-1, HYDERAABAD vs. DEENABABU KONDUBHATLA, HYDERABAD

Bench: Us :

TDS relating to Section 195. 3 3. During the course of assessment proceedings, the A.O. observed that the assessee had, during

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE 3(4), HYDERABAD

TDS), CPC had levied interest under section 201(1A), fee under section 234E and interest under section 220(2) of the Act for the reason that there was a delay in delivering/filing the statements within the time prescribed under section 200(3

THOTA RAMAIAH L/R T VASUNDHARA,HYDERABAD vs. ACIT, CIRCLE-4(1), , HYDERABAD

In the result, the appeal of the assessee is allowed

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

TDS Certificates etc. Ld. AR further submitted that section 40A(3) of the Act is applicable only to those expenditures

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