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7 results for “TDS”+ Section 80G(5)(iii)clear

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Key Topics

Section 143(3)11Addition to Income7Transfer Pricing6Section 10B4Section 92C4Section 144C(5)3Disallowance3Comparables/TP3Section 115J2Section 143(2)

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

In the result, appeal filed by the assessee is allowed

ITA 864/HYD/2017[2008-09]Status: DisposedITAT Hyderabad31 May 2023AY 2008-09

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.

For Appellant: Advocate Prathishta Singh &For Respondent: Dr.Rajendra Kumar, CIT-DR
Section 10BSection 115JSection 143(2)Section 143(3)Section 147
2
Section 1482
Natural Justice2
Section 148
Section 92C

5. The Ld. DRP/TPO erred in not appreciating that the amendment to section 92B would not apply to the year under consideration as it was inserted on a later date. The amendment has to be interpreted as prospective in nature. 6. The Ld. DRP/TPO erred in not appreciating the fact that Rain CII Carbon, LLC (RCC') had also provided guarantee

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 332/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

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

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 195(2)Section 40

TDS Credit of the transferor company to successor or transferee company even though the income of the transferor company is already considered by the successor company. 18.3 The Ld. AO erred in law and facts by not granting any TCS credit vis-à-vis INR 1,29,734/- as claimed by the Appellant in its Return of Income

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

Appeal is partly allowed in above terms

ITA 198/HYD/2021[2016-17]Status: DisposedITAT Hyderabad05 Oct 2021AY 2016-17

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

For Appellant: Dr.Sunil Moti Lala, ARFor Respondent: Shri D.Srinivas, DR
Section 143(3)Section 92C(3)

80G of the Act amounting to Rs. 7,91,500 while computing assessed taxable income in the computation sheet forming part of the assessment order. 17. On the facts and in the circumstances of the case and in law, the Ld AO erred in not granting of credit of tax deducted at source ('TDS ') amounting

BRIGHTCOM GROUP LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

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

ITA 1747/HYD/2019[2015-16]Status: DisposedITAT Hyderabad10 Sept 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Dr. Narendra Kumar Naik
Section 115JSection 143(2)Section 143(3)Section 144C(5)Section 14ASection 37Section 92C

III to the Companies Act, 2013.” 9.2 Thus, on perusal of above we find that there is no dispute on the fact that the assessee is engaged in rendering multiple services, including both digital marketing services and SDS. ITA No.1747/Hyd/2019 17 9.3 We have also gone through Note No. 16 relating to “Revenue from Operations” in the financial statements placed

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

ITA 227/HYD/2021[2016-17]Status: DisposedITAT Hyderabad03 Feb 2022AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri H. SrinivasuluFor Respondent: Shri YVST Sai
Section 143(3)Section 92C

80G of the Act amounting to INR 10,43,860 and further erred in not granting an opportunity of being heard to the Appellant, to present its case on merits, before denial of such deduction. 22. On the facts and circumstance of the case and in law, the Ld. AO erred by granting credit of tax deducted at source ('TDS

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

ITA 228/HYD/2021[2016-17]Status: DisposedITAT Hyderabad03 Feb 2022AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri H. SrinivasuluFor Respondent: Shri YVST Sai
Section 143(3)Section 92C

80G of the Act amounting to INR 10,43,860 and further erred in not granting an opportunity of being heard to the Appellant, to present its case on merits, before denial of such deduction. 22. On the facts and circumstance of the case and in law, the Ld. AO erred by granting credit of tax deducted at source ('TDS

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

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

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)

iii) Computing interest on invoice-to-invoice basis without computing weighted average receivable in days for all the invoices raised during the year under consideration and after considering receivables received in advance and the Hon'ble DRP further erred in upholding the said action of the Ld. TPO/AO 3. That on the facts and in the circumstances of the case