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)

TDS deducted on various expenses, the A.O. made addition of Rs. 2,23,33,770/- @ 30% of subcontract works of Rs. 7,44,45,893/- and added the same under Section

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)

TDS deducted on various expenses, the A.O. made addition of Rs. 2,23,33,770/- @ 30% of subcontract works of Rs. 7,44,45,893/- and added the same under Section

SRI SAI CONSTRUCTION CO,NIZAMABAD vs. DCIT., CIRCLE-1, NIZAMABAD

In the result appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

TDS was made on the above amount and there is no disallowance under section 40(a)(ia) of the Act, either in the ITR of the assessee are in the assessment order. The Assessing Officer failed to verify the above three issues in light of relevant facts which render the assessment order erroneous and prejudicial to the interests of Revenue

HCC CP PL JV,HYDERABAD vs. INCOME TAX OFFICER, WARD-14(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2018-19 Hcc Cp Pl Jv, Vs. The Income Tax Officer, Ward –14(1), Hyderabad. Hyderabad. Pan : Aaaah5541G. (Assessee) (Respondent) Assessee By: Shri Gvn Hari, Advocate (Appeared Through Hybrid Mode) Revenue By: Shri Srinath Sadanala, Sr.Dr Date Of Hearing: 06.02.2025 Date Of Pronouncement: 24.02.2025

7. Aggrieved by the order of LD.CIT(A), the assessee is in appeal before the Tribunal. 8. The Ld. AR for the assessee, Shri G.V.N. Hari, Advocate, submitted that the Ld. CIT(A) erred in upholding the denial of credit for TDS by the Assessing Officer without appreciating the fact that the provisions of Section

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 234E of the Act is cancelled. 7. In the result, all the appeals are allowed. Page 5 of 7 ITA Nos 494 to 499 Saubagya 6. In view of the above discussions and in view of the support drawn from the decision of Co-ordinate Bench of the Tribunal in the case of Garrison Engineer (E/M) Vs. JCIT (TDS

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 234E of the Act is cancelled. 7. In the result, all the appeals are allowed. Page 5 of 7 ITA Nos 494 to 499 Saubagya 6. In view of the above discussions and in view of the support drawn from the decision of Co-ordinate Bench of the Tribunal in the case of Garrison Engineer (E/M) Vs. JCIT (TDS

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 234E of the Act is cancelled. 7. In the result, all the appeals are allowed. Page 5 of 7 ITA Nos 494 to 499 Saubagya 6. In view of the above discussions and in view of the support drawn from the decision of Co-ordinate Bench of the Tribunal in the case of Garrison Engineer (E/M) Vs. JCIT (TDS

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 234E of the Act is cancelled. 7. In the result, all the appeals are allowed. Page 5 of 7 ITA Nos 494 to 499 Saubagya 6. In view of the above discussions and in view of the support drawn from the decision of Co-ordinate Bench of the Tribunal in the case of Garrison Engineer (E/M) Vs. JCIT (TDS

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD(TDS)-2(2),, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 234E of the Act is cancelled. 7. In the result, all the appeals are allowed. Page 5 of 7 ITA Nos 494 to 499 Saubagya 6. In view of the above discussions and in view of the support drawn from the decision of Co-ordinate Bench of the Tribunal in the case of Garrison Engineer (E/M) Vs. JCIT (TDS

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 234E of the Act is cancelled. 7. In the result, all the appeals are allowed. Page 5 of 7 ITA Nos 494 to 499 Saubagya 6. In view of the above discussions and in view of the support drawn from the decision of Co-ordinate Bench of the Tribunal in the case of Garrison Engineer (E/M) Vs. JCIT (TDS

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.:

section 201(1A) of the Act arises from failure to deposit TDS within the prescribed time and cannot be treated as expenditure incurred wholly and exclusively for business purposes. Accordingly, the Ld. DR prayed for upholding of the disallowance made by the Ld. AO. 7

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

Accordingly, the appeal filed by the assessee company, being devoid and bereft of any substance, is dismissed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1236 & 1237/Hyd/2025 ("नधा"रण वष"/Assessment Year:2021-22 & 2022-23) Vivimed Labs Limited, Vs. Dcit, Hyderabad. Central Circle-3(4), Pan: Aaacv6060A Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई क" तार"ख/Date Of 05/01/2026 Hearing: घोषणा क" तार"ख/Date Of 21/01/2026 Pronouncement: आदेश / Order

TDS statements. Vivimed Labs Limited vs. DCIT 7. Apropos the claim of the assessee company that the demands as contested were not tallying with the orders passed under section

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

TDS),\nCPC, Ghaziabad, considering the TDS/TCS statements passed orders under\nsection(s) 200A/206CB r.w.s 154 r.w.s 200A for the respective quarters,\nwherein demands under section 201(1A), 234E and 220(2) were raised, as\nunder:\nForm No.\nQuarter\nDate of Date of\nfiling of\nfiling of\nquarterly rectification\nreturn\nOrder u/s.\nby CPC\nDate of 234E

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

TDS and further\ndisallowance of EPF & ESI under Section 36(1)(va) for Rs.\n3,66,095/-, addition towards disallowance of interest expenditure\nunder Section 36(1)(iii) for Rs. 11,08,678/-, disallowance of\nexpenses claimed by the assessee under the head ‘trade discounts'\nand 'seed purchases' to the tune of Rs. 18,31,21,070/- and\naddition towards

DEPUTY COMMISSIONER OF INCOME TAX(IT)-II, HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, SECUNDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.725/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2015-16) Dy. C.I.T (It)-Ii Vs. Sew Infrastructure Ltd Hyderabad Secunderabad Pan:Aadcs4061P (Appellant) (Respondent) राज" व "ारा/Revenue By: Shri B Bala Krishna, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate सुनवाई की तारीख/Date Of Hearing: 22/10/2024 घोषणा की तारीख/Pronouncement: 28/10/2024 आदेश/Order

TDS for non-furnishing of PAN of non- resident. Further, this issue is also covered by the decision of the Hon'ble Delhi High Court in the case of CIT vs. Air India Ltd. (2022) 456 ITR 117 (Del.) where it has been clearly held that the provisions of section 206AA cannot have overriding effect on DTAA and in case

DIWAKAR LOGISTICS ,TADIPATRI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year:2014-15 M/S.Diwakar Logistics Vs. A.C.I.T Tadipatri Circle – 1 Pan:Aahfd0549E Anantapur (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri T. Sunil Goutam, Dr Date Of Hearing: 02/06/2022 Date Of Pronouncement: 05/08/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.12.2019 Of The Learned Cit (A)-Kurnool, Relating To A.Y.2014-15. 2. Fact Of The Case, In Brief, Are That The Assessee Is A Partnership Firm Engaged In The Business Of Transportation Of Goods & Filed Its Return Of Income On 29.11.2014 Declaring Total Income Of Rs.31,90,390/-. The Case Was Selected For Scrutiny. During The Course Of Assessment Proceedings, The Assessing Officer Noted That The Assessee Has Debited Finance Charges Of Rs.2,81,642/- & Transportation Charges Paid To Others Of Rs.74,57,350/-. The Assessing Officer Asked The Assessee To Page 1 Of 8

TDS statement within the time along with the details of PAN Nos. name and amount of credit etc., due to non- availability of the same. The provisions of section 194C(7

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. DIVI'S LABORATORIES LIMITED, HYDERABAD

In the result, appeal of the revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Asst. Commissioner Of Vs. Divi’S Laboratories Ltd., Income-Tax, Hyderabad. Central Circle – 2(1), Hyderabad. Pan – Aaacd 6745J (Appellant) (Respondent) Revenue By: Shri Anil S Assessee By: Shri S. Rama Rao Date Of Hearing: 20/07/2021 Date Of Pronouncement: 17/08/2021

section 234C) 11c 0 d Total Interest Payable (11a+11b+11c) 11d 0 12 Aggregate liability (10 + 11d) 12 0 13 Taxes Paid a Advance Tax (from Schedule-IT) 13a 0 b TDS (column 7

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD, HYDERABAD vs. SUSHEE PRASAD JV, HYDERABAD

In the result, the appeal of the revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 The Assistant Commissioner Of Vs. Sushee Prasad Jv, Hyderabad, Income Tax, Circle – 6(1), Plot No.246/A/2, Road Hyderabad. No.12, Mla Colony, Banjara Hills, Telangana – 500034. Pan : Aapas3540R. (Appellant) (Respondent) Assessee By: Shri S. Ramarao, Advocate. Revenue By: Shri Sesha Srinivas, Cit-Dr Date Of Hearing: 06.03.2024 Date Of Pronouncement: 12.03.2024

section. iii. The following details are noted from the copies of the returns of income and Form 26AS of the payees: 7 Name of the As per TDS