GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

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

2) of the Income-tax Act, 1961 dated 29.06.2021 was issued and served upon the assessee. Subsequently, the case was transferred to the Regional e-Assessment Centre under the Faceless Assessment Scheme, 2019. During the assessment proceedings, several notices under Section 142(1) of the Act were issued on 29.09.2022, 04.01.2023, 19.01.2023, and 28.07.2023, calling for details relating to business

YERRAM VENKATA SUBBA REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

Section 32(2) of the Act, the unabsorbed depreciation becomes the depreciation of the current year of the business and the same is eligible for set off against the individual income of the assessee u/s 170 of the Act as he is the successor to the business. ITA No.1119/Hyd./2018 A.Y.: 2013-14 Sh. Yerram Venkata Subba Reddy Therefore, ground

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.

13, 1963, wherein it was clarified that the successor would be entitled to the benefit of deduction under the old section 84, in respect of the unexpired period, and observing that though the circular was issued with reference to section 84, the same principle would apply to sections 80HH and 80-I and that too with greater force

COROMANDEL INTERNATIONAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

2) of section 10 of the Indian Income-tax Act, 1922 (11 of 1922), where such depreciation was not deductible in determining the written down value for the pur-poses of the said clause (vi);] [(c) in the case of any block of assets,— (i) in respect of any previous year relevant to the assessment year commencing

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

13) r.w.s.144B of the Income Tax Act [in short "the Act"], 1961. ITA.No.490/Hyd./2022 – A.Y. 2017-2018 : 2. The assessee has raised the following grounds of appeal: “General : 1. That on the facts and circumstances of the case, the final assessment order dated 30 July 2022 (received on 30 July 2022) passed by the Assessment Unit, Income Tax Department

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

13) r.w.s.144B of the Income Tax Act [in short "the Act"], 1961. ITA.No.490/Hyd./2022 – A.Y. 2017-2018 : 2. The assessee has raised the following grounds of appeal: “General : 1. That on the facts and circumstances of the case, the final assessment order dated 30 July 2022 (received on 30 July 2022) passed by the Assessment Unit, Income Tax Department

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE COOPERATIVE BANK LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE CO OPERATIVE BANK LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

DCIT., CIRCLE-8(1), HYDERABAD vs. DBS TECHNOLOGY SERVICES INDIA PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Deputy Commissioner Of Vs. M/S. Dbs Technology Income Tax, Services India Private Circle – 8(1), Limited, Hyderabad. Hyderabad. Pan : Aafcd5584N (Appellant) (Respondent) C.O.No.2/Hyd/2023 Assessment Year 2019-20 Dbs Technology Services India Vs. Deputy Commissioner Of Private Limited, Income Tax, Circle – 8(1), Hyderabad. Hyderabad. Pan : Aafcd5584N (Cross Objector / (Appellant/Revenue) Respondent) Assessee By: Sri M. P. Lohia, C.A. Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 11.07.2023 Date Of Pronouncement: 21.07.2023 आदेश / O R D E R Per Laliet Kumar, Jm: The Appeal & Cross-Objection Filed By The Revenue For A.Y. 2019-20 Arise From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi

13[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, 14[***] the report of an accountant, as defined in the Explanation below sub-section (2) of section 28815[before the specified date referred to in section 44AB], certifying that the deduction

UNION BANK OF INDIA (ERSTWHILE-ANDHRA BANK),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

2)(iii). 5. The learned Commissioner of Income Tax (Appeals) erred in law and on facts in remanding the issue to the learned Assessing Officer to re-work the depreciation on investments by considering earlier years opening stock and closing balances. ITA Nos.193 & 316/Hyd/2019 4 5.1 The learned Commissioner of Income Tax (Appeals) failed to appreciate the fact that

S & P CAPITAL IQ (INDIA) PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-3(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं / Ita-Tp No. 463/Hyd/2022 (निर्धारण वर्ा / Assessment Year: 2018-19)

depreciation on goodwill arising on amalgamation has already been dealt with by Hon'ble Supreme Court in the case of Smifs Securities (supra), which is later followed in various cases by the Hon’ble High Courts and Co-ordinate Benches of the Tribunal. 13. We find force in the submissions of the learned AR that Explanation 2 to Section

K LAXMA REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

13 of 26 ITA Nos 619, 621, 623 and 624 of 2019 K Vijaya Bhaskar Reddy & Other Hyd. Further, the statement of the assessee Mr. Vijaya Bhaskar Reddy, who is the director of the M/s. Cyber City Builders & Developers (P) Ltd, recorded during the course of search and thereafter including the affidavit on 1.6.2016 by Shri N. Jaiveer Reddy before

K VIJAYA BHASKAR REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

13 of 26 ITA Nos 619, 621, 623 and 624 of 2019 K Vijaya Bhaskar Reddy & Other Hyd. Further, the statement of the assessee Mr. Vijaya Bhaskar Reddy, who is the director of the M/s. Cyber City Builders & Developers (P) Ltd, recorded during the course of search and thereafter including the affidavit on 1.6.2016 by Shri N. Jaiveer Reddy before

N JAIVEER REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

13 of 26 ITA Nos 619, 621, 623 and 624 of 2019 K Vijaya Bhaskar Reddy & Other Hyd. Further, the statement of the assessee Mr. Vijaya Bhaskar Reddy, who is the director of the M/s. Cyber City Builders & Developers (P) Ltd, recorded during the course of search and thereafter including the affidavit on 1.6.2016 by Shri N. Jaiveer Reddy before