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

section 9(1 )(vii) r. w. Explanation 2 comes in between the words "managerial and consultancy services". We find that the principles laid down by the Delhi High Court have been accepted by the Apex Court as such and the Apex Court has merely directed the TDS

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

section 9(1 )(vii) r. w. Explanation 2 comes in between the words "managerial and consultancy services". We find that the principles laid down by the Delhi High Court have been accepted by the Apex Court as such and the Apex Court has merely directed the TDS

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

section 9(1 )(vii) r. w. Explanation 2 comes in between the words "managerial and consultancy services". We find that the principles laid down by the Delhi High Court have been accepted by the Apex Court as such and the Apex Court has merely directed the TDS

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

section 9(1 )(vii) r. w. Explanation 2 comes in between the words "managerial and consultancy services". We find that the principles laid down by the Delhi High Court have been accepted by the Apex Court as such and the Apex Court has merely directed the TDS

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

section 9(1 )(vii) r. w. Explanation 2 comes in between the words "managerial and consultancy services". We find that the principles laid down by the Delhi High Court have been accepted by the Apex Court as such and the Apex Court has merely directed the TDS

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

section 9(1 )(vii) r. w. Explanation 2 comes in between the words "managerial and consultancy services". We find that the principles laid down by the Delhi High Court have been accepted by the Apex Court as such and the Apex Court has merely directed the TDS

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

vii) of sub-section (1) of section 9; (iii) "professional services" shall have the same meaning as in clause (a) of the Explanation to section 194J; (iv) "work" shall have the same meaning as in ExplanationIII to section 194C; 55[(v) "rent" shall have the same meaning as in clause (i) to the Explanation to section

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

In the result, assessee's appeals for the A

vii)\nAny other grounds that may be urged at the time of hearing.\nITA No.284/Hyd/2024 A.Y (2016-17)- (Assessee)\n1. Your Appellant submits that the provision of Section 40A(9) are not applicable to the\nfacts of the case, being reimbursement/grant of deficit in the actual expenditure\nincurred by schools run by Singareni Educational Society, which is welfare\nexpenditure

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSPIRA MANAGEMENT SERVICES PRIVATE LIMITED , HYDERABAB

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Dcit, Vs. M/S. Nspira Management Circle-16(1) Services Private Limited, Hyderabad. Hyderabad.

9(1)(vii) of the Act which clearly mentions that the ‘fee for technical services’ would include managerial, technical or consultancy services and the services rendered by the said Singaporean companies to the assessee would fall within the scope of ‘fee for technical services’. 6. The ld.DR further drawn our attention to the paragraphs 4.3 and 4.6 of the assessment

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

9,70,04,260/- after claiming the deduction u/s. 80IA at Rs. 12,60,23,062/- from the gross total income of Rs.22,30,27,300/-. He submitted that the assessee had filed the original return within the statutory due date and the revised return was also filed before the statutory due date as prescribed under section

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

9,70,04,260/- after claiming the deduction u/s. 80IA at Rs. 12,60,23,062/- from the gross total income of Rs.22,30,27,300/-. He submitted that the assessee had filed the original return within the statutory due date and the revised return was also filed before the statutory due date as prescribed under section

PROGRESSIVE CONSTRUCTIONS LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.625/Hyd/2025 Assessment Year 2021-2022 Progressive Constructions The Dcit, Limited, Hyderabad. Circle-5(1) Vs. Pin – 500 001. Telangana. Hyderabad - 500 004. Pan Aabcp2274M Telangana. (Appellant) (Respondent) Ca Pawan Kumar Chakrapani िनधा"रती "ारा/Assessee By : & Sri Santi Pavan Kumar, Advocate राज" व "ारा/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 02.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

vii) subject to the provisions of sub-section (2), the amount of any bad debt or part thereof which is written off as irrecoverable in the accounts of the assessee for the previous year." This position in law is well-settled. April, 1989, it is not necessary for the assessee establish that the debt, in fact, to has become irrecoverable

ACIT, CENTRAL CIRCLE-2(1), HYDERABAD vs. TRIDENT CHEMPHAR LIMITED, HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Asst. Commissioner Of Income Vs. M/S. Trident Chemphar Ltd. Hyderabad. Tax, Central Circle – 2(1), Pan : Aaeft8416H. Hyderabad. (Appellant) (Respondent) Assessee By: Shri B.G. Reddy Revenue By: Shri Rajendra Kumar – Cit-Dr Date Of Hearing: 09.01.2023 Date Of Pronouncement: 09.01.2023

Section 9(1)(vii) of the Act. The jurisdictional ITAT, Hyderabad in M/s.Vimta Labs Ltd, Hyderabad vs DCIT, Circle-7(2), Hyderabad (ITA Nos.11, 12 & 1273/2017) dated 24/04/2019 has discussed this issue elaborately and held that the business receipts of foreign residents are not taxable in India since the agents have no PE in India and therefore are not required

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

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

Bench: Shri Manjunatha G.\Nand\Nshri Ravish Sood\Nआ.अपी.सं /Ita No.917/Hyd/2024\N(निर्धारण वर्ष/Assessment Year:2020-21)\Nshakti Hormann Private\Nlimited,\Nhyderabad.\Nvs. Dcit,\Ncircle-3(1),\Nhyderabad.\Npan: Aadcs4024Q\N(Appellant)\N(Respondent)\Nनिर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao,\Nca\Nराजस्व द्वारा / Revenue By: Ms. U. Mini Chandran,\Ncit-Dr\Nसुनवाई की तारीख /Date Of Hearing: 15/10/2025\Nघोषणा की तारीख / Date Of 19/12/2025\Npronouncement:\Nआदेश / Order\Nper. Ravish Sood, J.M:\Nthe Present Appeal Filed By The Assessee Company Is Directed\Nagainst The Final Assessment Order Passed By The Assessing Officer (For\Nshort, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The\Nincome Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The\N Assessment Year (Ay) 2020-21. The Assessee Company Has Assailed\Nthe Impugned Order Passed By The Cit(A) On The Following Grounds Of\Nappeal Before Us:\N1. On The Facts & In The Circumstances Of The Case, The Final Assessment\Norder Passed U/S 143(3) R.W.S.144C(13) Of The Act Dated 25.07.2024 By\Nthe Ao & Also The Order Passed U/S 92Ca (3) Dt 30.07.2023 By The Tpo\Nare Bad In The Eyes Of Law & Thus, Unsustainable To The Test Of Appeal.\N2.0 The Final Assessment Order Passed U/S 143(3) R.W.S.144C(13) R.W.S.144B\Nis Beyond The Time Limit Prescribed U/S 153 Of The Act.\N2.

TDS related\ndisallowances; and (vii) prior year adjustments. After necessary\nverifications, the AO accepted the assessee's explanation on the issues\nother than the TP adjustment that was suggested by the TPO.\n6. The AO thereafter issued a draft assessment order under section\n144C(1) of the Act, dated 26/09/2023, wherein, after incorporating the\nTP adjustments, he proposed to assess

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 :

1 (ii) is dismissed accordingly to the extent of quantification above. The ground no. 4 relates to the claim of the appellant that the income tax refund should have been reduced while computing the book profit u/ s. 115JB. The section 115JB does not leave any room for discretion or interpretation and the items mentioned in clause (i) to (viii

SHELADIA ASSOCIATES INC,SECUNDERABAD vs. ADIT (INT TAXN)-2, HYDERABAD

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1401/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2022-23) Sheladia Associates Inc. Vs. Adit (International Secunderabad Taxation)-2 Pan : Aafcs7792F Hyderabad

1)(vii) makes it clear that the fee for technical services means any consideration for rendering of any managerial, technical or consultancy services, including the provision of services of technical or other personnel. The assessee has strongly raised upon the definition of FTS provided in Article 12 of Indo-US DTAA. For ready reference, Article 12 of Indo-US DTAA