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

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

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

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

In the result, appeal filed by the assessee is allowed

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.

capital in nature, without appreciating that the same qualifies as interest under the provisions of the Income-tax Act, 1961 and the Appellant had also deducted tax at source in respect of finance charges. 18. Without prejudice to the above, assuming without admitting. even if the interest and finance charges in relation to global acquisition is considered to benefit