ACIT., EXEMPTIONS CIRCLE-1(1), HYDERABAD vs. PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025

charitable purposes. The substantial question of law is thus answered in favour of the assessee in so far as the payment of taxes under the VDIS is concerned and in favour of the Revenue so far as the expenditure incurred outside India (Germany) is concerned. 32. The next question which arises is regarding the applicability of Section

POWER MECH PROJECTS LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(3), HYDERABAD

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

charitable trust registered u/s 80G(5) of the Act. Tax Treatment: The entire CSR expenditure of Rs.2 crores is to be disallowed and added back in terms of Explanation 2 to Section 37(1

DELOITTE & TOUCHE ASSURANCE & ENTERPRISE RISK SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals are allowed

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

charitable trust registered u/s 80G(5) of the Act. Tax Treatment: The entire CSR expenditure of Rs.2 crores is to be disallowed and added back in terms of Explanation 2 to Section 37(1

DELOITTEE TAX SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals are allowed

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

charitable trust registered u/s 80G(5) of the Act. Tax Treatment: The entire CSR expenditure of Rs.2 crores is to be disallowed and added back in terms of Explanation 2 to Section 37(1

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

charitable trust registered u/s 80G(5) of the Act. Tax Treatment: The entire CSR expenditure of Rs.2 crores is to be disallowed and added back in terms of Explanation 2 to Section 37(1

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

charitable trust registered u/s 80G(5) of the Act. Tax Treatment: The entire CSR expenditure of Rs.2 crores is to be disallowed and added back in terms of Explanation 2 to Section 37(1

M.G.R.EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD

1) are\nthus not directly relevant in this regard. \"Nothing contained in\nsection 11 or section 12 shall operate so as to exclude, from the\ntotal income of the previous year, of the person which clearly\nenvisages operation of section 11 or section 12 before the\nprovisions of section 13 can be applied or invoked in a given case

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

MARUTHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

MARRI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

1) are thus not directly relevant in this regard. "Nothing contained in section 11 or section 12 shall operate so as to exclude, from the total income of the previous year, of the person which clearly envisages operation of section 11 or section 12 before the provisions of section 13 can be applied or invoked in a given case