NUNHEMS INDIA PRIVATE LIMITED,R.R.DIST vs. JCIT, RANGE 16, HYDERABAD

In the result, the assessee’s appeal for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

VII) OF THE ACT. WHETHER THE PAYMENT TO FTOS FOR 'IUC'S ARE IN THE NATURE OF ROYALTY UNDER SECTION 9(1)(VI) OF THE ACT. WHETHER THE ASSESSEE IS LIABLE TO BE TREATED AS ASSESSEE IN DEFAULT U/S. 201 OF THE I.T. ACT. WHETHER THE PAYMENT MADE BY THE ASSESSEE TO THE FTO CAN BE DEEMED TO ACCRUE

NUNHEMS INDIA PRIVATE LIMITED,,HYDERABAD vs. ASST.CIT,CIRCLE 16(1),,

In the result, the assessee’s appeal for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

VII) OF THE ACT. WHETHER THE PAYMENT TO FTOS FOR 'IUC'S ARE IN THE NATURE OF ROYALTY UNDER SECTION 9(1)(VI) OF THE ACT. WHETHER THE ASSESSEE IS LIABLE TO BE TREATED AS ASSESSEE IN DEFAULT U/S. 201 OF THE I.T. ACT. WHETHER THE PAYMENT MADE BY THE ASSESSEE TO THE FTO CAN BE DEEMED TO ACCRUE

NUNHEMS INDIA PVT.LTD.,,R.R.DIST vs. ADDL.CIT, RANGE-16, HYDERABAD

In the result, the assessee’s appeal for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

VII) OF THE ACT. WHETHER THE PAYMENT TO FTOS FOR 'IUC'S ARE IN THE NATURE OF ROYALTY UNDER SECTION 9(1)(VI) OF THE ACT. WHETHER THE ASSESSEE IS LIABLE TO BE TREATED AS ASSESSEE IN DEFAULT U/S. 201 OF THE I.T. ACT. WHETHER THE PAYMENT MADE BY THE ASSESSEE TO THE FTO CAN BE DEEMED TO ACCRUE

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 254(1) of the 1961 Act,), the Tribunal was not authorized to take back the benefit granted to the assessee by the Assessing Officer. The Tribunal has no power to enhance the assessment.” 30.1 In view of the above discussion and in view of the detailed reasoning given by the ld.CIT(A), we do not find any infirmity

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 254(1) of the 1961 Act,), the Tribunal was not authorized to take back the benefit granted to the assessee by the Assessing Officer. The Tribunal has no power to enhance the assessment.” 30.1 In view of the above discussion and in view of the detailed reasoning given by the ld.CIT(A), we do not find any infirmity

VICTORY ELECTRICALS LIMITED, MEDCHAL,R.R.DIST vs. DCIT, CIRCLE-17(2), HYDERABAD, HYDERABAD

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2012-13 Victory Electricals Ltd., V Dcit,Circle-17(2) Plot No.8, Survey No.855, S. Signature Towers Ida, Medchal, Kondapur Ranga Reddy, Hyderabad Hyderabad-501 401

section 36(1)(vii) of the Act, Our attention was drawn to reply given by the assessee, more particularly at page No.53 & 54 to the following effect “In continuation of the statement of facts, the appellant may be permitted to submit the following explanation: There are three effective grounds in all. The first ground is with regard to disallowance

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-9(1), HYDERABAD vs. TELANGANA GRAMEENA BANK(EARLIER KNOWN AS M/S DECCAN GRAMEENA BANK), HYDERABAD

In the result, appeals filed by the Revenue are dismissed and the assessee’s C

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

36 the aforesaid amount shall be computed with reference to the income credited or paid by a branch of the banking company or the co-operative society or the public company, as the case may be : Provided further that the amount referred to in the first proviso shall be computed with reference to the income credited or paid

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-9(1), HYDERABAD vs. TELANGANA GRAMEENA BANK (EARLIER KNOWN AS M/S DECCAN GRAMEENA BANK), HYDERABAD

In the result, appeals filed by the Revenue are dismissed and the assessee’s C

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

36 the aforesaid amount shall be computed with reference to the income credited or paid by a branch of the banking company or the co-operative society or the public company, as the case may be : Provided further that the amount referred to in the first proviso shall be computed with reference to the income credited or paid

MANNE HAREESH,HYDERABAD vs. INCOME TAX OFFICER 6(2), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri S.S. Godara & Shri L. P. Sahu(Through Virtual Hearing) Shri Manne Hareesh, Income Tax Officer, Hyderabad-500 0016 Ward 6(2), Pan Admpm6479L Hyderabad. (Appellant) (Respondent) Assessee By: Shri T.Rama Murthy, C.A. Revenue By: Shri Sunil Kumar Pandey (D.R) Date Of Hearing: 21/04/2021 Date Of Pronouncement: 16/08/2021 O R D E R Per L.P.Sahu, A.M. : This Is An Appeal Filed By The Assessee Against The Order Of Commissioner Of Income Tax-6, Hyderabad Order Dt.10.10.2019 For The Assessment Year 2012-13 Raising The Following Grounds Of Appeal : “ 1. The Learned Commissioner Of Income Tax - Appeals Erred Both On Facts & Provisions Of Law In Appreciating The Fact That Assessing Officer Failed Make Proper Conclusion/ Enquiry Before Making The Addition Made & Passing The Assessment Order.

Section 36(1)(vii) of the Income Tax Act, 1961 ('the Act'). Accordingly, the case was reopened u/s.147/148 and thereafter other statutory notices were issued to the assessee. During the course of reassessment proceedings, it was asked the assessee to file details of services rendered by the marketing professionals along with bills, vouchers and receipts indicating dealing of sales promotion

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

vii. erred in application of "the other method" without determining any arm's length price. viii. erred in concluding that the Appellant failed to comply with the subsection (1) and (2) of 92C of the Act. Corporate tax matters 6.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in disallowing the expenditure

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

vii. erred in application of "the other method" without determining any arm's length price. viii. erred in concluding that the Appellant failed to comply with the subsection (1) and (2) of 92C of the Act. Corporate tax matters 6.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in disallowing the expenditure

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

TDS credit as per law. The above ground is allowed to that extent accordingly. The Ground nos. 6 & 7 are consequential to the grounds adjudicated above, therefore needs no separate adjudication. To sum up the appeal is partly allowed.” 5. Feeling aggrieved by the order passed by the ld.CIT(A), the Revenue is now in appeal before

CAMBRIDGE TECHNOLOGY ENTERPRISES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result assessee’s appeal stand partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

36(1) (vii) of the IT Act relating to Bad debts and treated the same as capital loss, without appreciating the fact that the same is related to business of assessee, which was offered to tax as income on mercantile system. 5.3. Erred in not appreciating the fact that the sale amount which has become irrecoverable has been written

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

1. erred in determining the income of the Appellant at INR 31,99,82,158 as against returned income of INR 28,40,73,030 for the year under consideration. VALIDITY OF FINAL ORDER PASSED BEYOND TIMELINES PRESCRIBED UNDER SECTION 153 OF THE ACT 2. erred in not passing the final assessment order within the time limit prescribed under section

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. DCIT., CIRCLE-13(1), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.283, 284 & 286/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं / Ita Nos.300, 301 & 308/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. Cit, Circle 13(1) Hyderabad Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 10/06/2025 घोषणा की तारीख / Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

vii) Any other grounds that may be urged at the time of hearing. ITA No.286/Hyd/2024 (A.Y 2020-21) - (Assessee) 1. Your Appellant submits that the provision of Section 40A(9) are not applicable to the facts of the case, being reimbursement/grant of deficit in the actual expenditure incurred by schools run by Singareni Educational Society, which is welfare expenditure

INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE -2(1), HYDERABAD

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

vii) Suprawin Technologies Limited viii) Sundaram Business Services Pvt Limited ix) Tata Consulting Engineers Limited x) Tata Elxsi Limited xi) Cosmic Global Limited xii) BNR Udyog Limited 7. Without prejudice to the above grounds on incorrect selection of functionally dissimilar comparable companies while benchmarking the ITES Services (ITeS) segment of the Appellant, on the facts and in the circumstances

CYBERMATE INFOTEK LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(4), HYDERABAD

In the result, appeal of the assessee allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2013-14 Cybermate Infotek Ltd., Vs. Income-Tax Officer, Hyderabad. Ward – 1(4), Hyderabad. Pan – Aabcc 4776F (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai Date Of Hearing: 24/08/2021 Date Of Pronouncement: 21/09/2021

TDS from the payment made towards legal and professional fee. The Hon’ble Delhi High Court in the case of CIT vs. Ansal Land Mark Township (P.) Ltd [2015] 61 taxmann.com 45 (Delhi), has considered the applicability of second proviso to section 40(a)(ia) of the Act and held that the second proviso to section

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

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

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

section is very clear and the appellant has incurred the expenditure and the appellant has made the payment to the various parties and persons. The appellant has, to circumvent, not accounted for the same and has also not brought out any evidence from M/s.DLF that they have accounted for such transactions in their books as cash payments. The MoU cannot

KRISHNA CONSTRUCTIONS,NIRMAL vs. INCOME TAX OFFICER, WARD-1, NIRMAL

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1330/Hyd/2025 Assessment Year 2017-2018 Krishna Constructions The Income Tax Officer, Nirmal. Telangana. Ward-1, Vs. Pin – 504 106. Nirmal – 504 106. Pan Aapfk1280K Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri D Prabhakar Reddy, Advocate राज" व "ारा/Revenue By : Dr. Sachin Kumar,Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10.03.2026 घोषणा की तारीख/Pronouncement: 08.04.2026 आदेश/Order Per Vijay Pal Rao:

vii. On the facts and in the circumstances of the case, and in law, the Ld. CIT(Appeals) erred in confirming the action of the Ld. AO in treating the investment made by the partners into the firm out of their contract income of Rs.2,20,45,610/- as the income of the assessee. viii. On the facts