VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

IA of the Act furnished during the course of revision proceedings. The Appellant craves leave to add, alter, amend, rescind and modify the grounds herein above or produce further documents, facts and evidence before or at the time of hearing of this appeal. For the above and any other grounds which may be raised at the time of hearing

LANCO SOLAR (GUJARAT) PRIVATE LIMITED ,HYDERABAD vs. ITO., WARD-16(1), HYDERABAD

In the result, appeals filed by the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

gains derived from any industrial undertaking or business of a hotel from any ship, to which this section applies, as does not exceed six per cent per annum on the capital employed in such undertaking or business or ship. computed in the prescribed manner. (2) This section applies to any industrial undertaking which fulfills all the following conditions, namely

LANCO SOLAR (GUJARAT) PRIVATE LIMITED ,HYDERABAD vs. ITO., WARD-16(1), HYDERABAD

In the result, appeals filed by the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

gains derived from any industrial undertaking or business of a hotel from any ship, to which this section applies, as does not exceed six per cent per annum on the capital employed in such undertaking or business or ship. computed in the prescribed manner. (2) This section applies to any industrial undertaking which fulfills all the following conditions, namely

DATAFORMIX ENTERPRISE SOLUTIONS PRIVATE LIMITED ,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2013-14 Dataformix Enterprise V Ito,Ward-17(1) Solutions Private Limited S. Signature Towers 1-33-47, Rtc Colony, Kondapur Gunrock, Tirumalgiri Hyderabad-500 004 Secunderabad-500 0074

section 37 of the act. 9. In the present case, though the nature of expenditure are primarily in the nature of salary however that salary expenses were laid by the assessee for the purposes of developing a capital asset in the form of the software for its own purposes . Therefore the expenditure in question was capital in nature

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED., HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED , HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED , HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this