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.

depreciation by VITP has already been inquired by the Assistant Commissioner of Income Tax (e-verification) vide notice dated September 27, 2019 issued under Section 143(2) of the Act (Copy enclosed as Annexure 10A

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

10A by restricting the profit from the eligible business of assessee to 20% of the turnover. In our view, the Department having not fulfilled the conditions of section 80IA(10), disallowance in the present case is not justified. At the cost of repetition, it needs to be stated that only relying upon TP documentation, AO has inferred that the profit

CORTEVA AGRISCIENCE SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

In the result, the Ground No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 10AA of the Act does not explicitly provide the time line for realization of export proceeds. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 3. Brief facts of the case is that

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

10A or section 10AA or section 10B or section 10BA or under any provision of this Chapter under the heading “C-Deductions in respect of certain incomes”, no deduction shall be allowed to him thereunder Section 80AC Deduction not to be allowed unless furnished-Where in computing the total income of an assessee of the previous year relevant

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

10A or section 10AA or section 10B or section 10BA or under any provision of this Chapter under the heading “C-Deductions in respect of certain incomes”, no deduction shall be allowed to him thereunder Section 80AC Deduction not to be allowed unless furnished-Where in computing the total income of an assessee of the previous year relevant

ROLON SEALS INTERNATIONAL,HYDERABAD vs. ITO., WARD-11(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.947/Hyd/2025 Assessment Year 2023-2024 Rolon Seals International, The Income Tax Officer, Hyderabad – 500 063. Vs. Ward-11(1), Telangana. Hyderabad. Pan Aarfr2216G (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Sashank Dundu, Advocate राज" व "ारा /Revenue By: G Saratha, Sr. Ar

10A of the I.T. Act applicable to the exemption u/s 10AA of the 1.T. Act reads as follows:- "(5) The deduction under this section shall not be admissible for any assessment year beginning on or after the 1st day of April, 2001, unless the assessee furnishes in the prescribed form, 59[***] the report of an accountant, as defined

ELICO LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-2(2), HYD, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singh

depreciation brought forwarded from the AY.2007- 08, net effect of the same would be loss. Following the CBDT Circular No.07/2013, dt.16th July, 2013, the CIT(A) held that profit or loss from various sources i.e., from eligible and non- eligible units under the same head have to be aggregated in accordance with the provisions of Section