ITO, WARD-4(2), HYDERABAD, HYDERABAD vs. SUBRAHMANYAM KOTIKALAPUDI, HYDERABAD, HYDERABAD

In the result, appeal of the revenue is dismissed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2013-14 Income-Tax Officer, Vs. Subrahmanyam Kotikalapudi, Ward – 4(2), Hyderabad. Hyderabad.

290/-. The case was selected for scrutiny under CASS to examine the large deduction claimed u/s 54B, 54C, 54D, 54G and 54GA. Against the notice u/s 143(2) issued by the AO, the AR of the assessee filed the required information. 2.1 The AO observed that the assessee claimed deduction u/s 54EC to the extent

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

290 (Del.) and submitted that the Hon'ble Delhi High Court has considered an identical issue of 80IA and held that a mere change of ownership/ pattern of shareholding does not make any difference for the benefit u/s 80IA of the Act available to the undertaking because the undertaking continue to carry on business without any re-construction of business

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

290 (Del.) and submitted that the Hon'ble Delhi High Court has considered an identical issue of 80IA and held that a mere change of ownership/ pattern of shareholding does not make any difference for the benefit u/s 80IA of the Act available to the undertaking because the undertaking continue to carry on business without any re-construction of business

ROCKSALT INTERACTIVE GAMES PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-3(2) , HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarm/S. Rocksalt Interactive Income Tax Officer, Vs. Games Pvt. Ltd., Ward 3(2), Hyderabad. Hyderabad. Pan Aafcr3033A (Appellant) (Respondent) Appellant By : Shri P. Murali Mohan Rao, C.A. Respondent By : Shri Vijay Bhaskar Reddy, Cit-Dr Date Of Hearing : 16.11.2022 Date Of Pronouncement : 12.12.2022 O R D E R Per Shri Laliet Kumar, J.M. : This Appeal Filed By The Assessee Is Directed Against The Order Dt.30.03.2020 Of The Learned Pr. Commissioner Of Income Tax/Cit-3, Hyderabad Relating To Assessment Year 2015-16 U/S. 263 Of The Income Tax Act, 1961 (In Short ‘The Act’).

Capital gains" and claims that the loss or any part thereof should be carried forward under subsection (1) of section 72, or sub-section (2) of section 73, or sub-section (2) of section 73A or sub-section (1) or sub-section (3) of section 74, or sub-section (3) of section 74A, he may furnish, within the time allowed

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is partly allowed

gain on account of foreign exchange fluctuation of Rs.15,46,428 as income from other sources; (ii) to disallow gratuity of Rs.1,32,95,577; and (iii) to disallow expenditure amounting to Rs.2,69,26,757 relatable to issue of foreign currency convertible bonds. Aggrieved by the order of the Ld. CIT under section

TAURUS VALUE STEEL & PIPES PVT LTD,RANGA REDDY vs. DCIT, CIRCLE-2(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

2 of 7 in respect of income from Long Term Capital Gain, sale of land, income from Short Term Capital Gain on the sale of machinery and income from other sources apart from denying the set-off of losses to the tune of Rs. 18.37 crores. 5. Aggrieved, assessee challenged the same before the learned CIT(A) on the following

M/S COUNTRY CLUB INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(2), HYDERABAD, HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmancountry Club Hospitality & Vs Dy. Commissioner Of Income Holidays Ltd (Formerly Tax, Circle 3 (2) Known As Country Club Hyderabad India Ltd) Hyderabad Pan: Aaacc8276B (Appellant) (Respondent)

gain on account of foreign exchange fluctuation of Rs.15,46,428 as income from other sources; (ii) to disallow gratuity of Rs.1,32,95,577; and (iii) to disallow expenditure amounting to Rs.2,69,26,757 relatable to issue of foreign currency convertible bonds. Aggrieved by the order of the Ld. CIT under section

DY.CIT, CIR-1(2), HYDERABAD vs. M/S CUNTRY CLUB (I) LIMITED,, HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

gain on account of foreign exchange fluctuation of Rs.15,46,428 as income from other sources; (ii) to disallow gratuity of Rs.1,32,95,577; and (iii) to disallow expenditure amounting to Rs.2,69,26,757 relatable to issue of foreign currency convertible bonds. Aggrieved by the order of the Ld. CIT under section

M/S. COUNTRY CLUB INDIA LTD.,,HYDERABAD vs. ACIT, CIRCLE-1(2), HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

gain on account of foreign exchange fluctuation of Rs.15,46,428 as income from other sources; (ii) to disallow gratuity of Rs.1,32,95,577; and (iii) to disallow expenditure amounting to Rs.2,69,26,757 relatable to issue of foreign currency convertible bonds. Aggrieved by the order of the Ld. CIT under section

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-9(1), HYDERABAD vs. VEDULA VENKATA RAMANA, L/R OF LATE SMT. V. RAJYALAKSHMI,, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

2 of 9 6. Learned Assessing Officer obtained information from other sources also. He concluded the assessment by order dated 30/12/2016 passed under section 143(3) read with section 147 of the Act, adding the amount of Rs. 12.16 crores in the hands of the assessee in his individual capacity, which the assessee challenged before the learned

INCOME TAX OFFICER (INTERNATIONAL TAXATION)-1, HYDERABAD vs. ARUNA GULLAPALLI, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Income Tax Officer, Vs. Aruna Gullapalli, (International Taxation) – 1, Hyderabad. Hyderabad. Pan No.Bfhpg9489L. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Kumar Adithya Date Of Hearing: 23.01.2023 Date Of Pronouncement: 31.01.2023

capital gain disallowing cost of acquisition as well as deduction towards 54F and Rs.1,85,00,000/- towards unexplained investment u/s 69 of the Act and thus assessed the total income at Rs.4,89,28,400/-. 4. Feeling aggrieved with the order of Assessing Officer, assessee carried the matter before ld.CIT(A) who passed order in favour of the assessee

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

gain of Rs. 106,68,32,843 from the profits of the business instead of considering the net amount of Rs. 63,66,53,406 credited to profit & loss account for the purpose of computing deduction under section 10A of the Act. Computing incorrect amount of interest under section 234D of the Act. ITA Nos.1613 & 1632/Hyd/2017 Page

SLR INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

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

290/-. The case has been selected for scrutiny for verification of genuineness of expenses and the assessment has been completed under Section 143(3) r.w.s.143(3A) & 143(3B) of the Income Tax Act, 1961 on 09-04-2021 and accepted the income returned by the assessee.\n\n3. The case has been, subsequently taken up for revision proceedings. A Show

VIVIMED LABS LIMITED,HYDERABAD vs. 500082 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

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

2(24) of Income Tax Act, 1961 and when a receipt is not on in the character of income it cannot form part of the book profit under Section 115JB of the Act, 1961. In the case of AppolloTyres Ltd. (supra) the income in question was taxable but was exempt under a specific provision of the Act as such

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

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

2(24) of Income Tax Act, 1961 and when a receipt is not on in the character of income it cannot form part of the book profit under Section 115JB of the Act, 1961. In the case of AppolloTyres Ltd. (supra) the income in question was taxable but was exempt under a specific provision of the Act as such

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX , HYDERABAD

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

2(24) of Income Tax Act, 1961 and when a receipt is not on in the character of income it cannot form part of the book profit under Section 115JB of the Act, 1961. In the case of AppolloTyres Ltd. (supra) the income in question was taxable but was exempt under a specific provision of the Act as such

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

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

2(24) of Income Tax Act, 1961 and when a receipt is not on in the character of income it cannot form part of the book profit under Section 115JB of the Act, 1961. In the case of AppolloTyres Ltd. (supra) the income in question was taxable but was exempt under a specific provision of the Act as such

KALAWATHI BAGAYATH,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, both the appeal of the assessee in ITA

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

2. In this appeal the assessee has raised 11 (1 to 11) grounds of appeal and raised additional grounds off appeal from 12 to 17, the sum and substance of which are against the action of the CIT(A) in upholding the computation of long term capital gains

KALAWATHI BAGAYATH,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, both the appeal of the assessee in ITA

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

2. In this appeal the assessee has raised 11 (1 to 11) grounds of appeal and raised additional grounds off appeal from 12 to 17, the sum and substance of which are against the action of the CIT(A) in upholding the computation of long term capital gains