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

depreciation on the same. 7.1. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred disallowing the foreign remittance made towards R&D Services availed from Dr. Reddy's Research & Development B.V. (formerly known as Octoplus B.V.) and Support services avalled from Dr Reddy's Laboratories Inc USA under section

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

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

depreciation and allowances are dealt with in Section 32. Therefore, Parliament has used the expression "any expenditure" in Section 37 to cover both. Therefore, the expression "expenditure" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket

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:

13 of 17 Coromandel International Limited Vs. DCIT 16.4. On perusal of above, we find that the said proviso provides that in the case of amalgamation, the total depreciation allowable to the amalgamating company and the amalgamated company for the previous year in which such amalgamation takes place shall not exceed the amount of depreciation that would have been allowable

BSCPL AURANG TOLLWAY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay, wherein it was submitted that the appeal for the relevant assessment year was required to be filed within 60 days from the date of receipt of the order passed under Section 263 of the Income-tax Act, 1961. However, the

3) r.w.s. 143(3A) and Section 143(3B) on 15.04.2021 in allowing the excessive depreciation on cost incurred for development of toll road as intangible asset is prejudicial to the interest of the Revenue, and thus, opined that, the assessment order passed by the A.O. is erroneous insofar as it is prejudicial to the interest of 10 BSCPL Aurang Tollway

COMMVAULT SYSTEMS INDIA PVT. LTD., HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD

Appeal is treated as allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singhassessment Year: 2012-13 M/S Commvault Systems Dcit, Circle 1(2) (India) Private Limited Vs. Hyderabad 5Th Floor, Plot No.39, Phase Ii Block A, Ananth Info Park Hitech City, Madhapur Hyderabad Pan: Aaccc3708L (Appellant) (Respondent) Sh. Ajeet Tolani Asessee By: Revenue By: Smt. Anjala Sahu, D.R. Date Of Hearing: 01/09/2020 Date Of Pronouncement: 04/09/2020 Order Per Smt. P. Madhavi Devi, J.M. This Is An Appeal Filed By The Assessee For The A.Y. 2012-13 Against The Final Assessment Order Dated 26.12.2016 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T. Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Company, Engaged In The Business Of Software Development Services & Unified Data Storage Solutions, E-Filed Its Original Return Of Income For The A.Y. 2012-13 On 11.10.2012 Admitting Total Income Of

13) of the I.T. Act, 1961. 2. Brief facts of the case are that the assessee company, engaged in the business of software development services & unified data storage solutions, e-filed its original return of income for the A.Y. 2012-13 on 11.10.2012 admitting total income of ITA No.160/Hyd/2017 AY 2012-13 M/s Commvault Systems India P Ltd. Hyd. Rs.2

PONAPULA SULOCHANA LR LATE P SANJEEVA PARTHASARATHY,HYDERABAD vs. ASSISTANT COMMISSIONER OF TAX ,CENTRAL CIRCLE-3(2), HYDERABAD

In the result, the appeal of assessee for A

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

depreciation and business losses are governed by Section 72 r.w.s. 80 of the Income Tax Act, 1961. As per Section 80 of the Act, no loss which has not been determined in pursuance of a return filed in accordance with the provisions of Section 139(3) shall be carry forward and set off under Section

PONNAPULA SULOCHANA, L/R OF LATE PONNAPULA SANJEEVA PARTHASARATHY,HYDERABAD vs. ACIT ,CENTRAL CIRCLE -3(2), HYDERABAD

In the result, the appeal of assessee for A

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

depreciation and business losses are governed by Section 72 r.w.s. 80 of the Income Tax Act, 1961. As per Section 80 of the Act, no loss which has not been determined in pursuance of a return filed in accordance with the provisions of Section 139(3) shall be carry forward and set off under Section

SHRI GAYATRI CONSTRUCTIONS,NELLORE vs. DCIT., CIRCLE-1, NELLORE

In the result, the appeal of assessee for A

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

depreciation and business losses are governed by Section 72 r.w.s. 80 of the Income Tax Act, 1961. As per Section 80 of the Act, no loss which has not been determined in pursuance of a return filed in accordance with the provisions of Section 139(3) shall be carry forward and set off under Section

MYLAN LABORATORIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

3 of section 32(1) and in support of his contention, he placed reliance upon the decision of the coordinate bench of the Tribunal in the case of AP Paper Mills Ltd., 128 TTJ 596 (Hyd.) and also the decision of the Hon’ble Delhi High Court in the case of Areva T&D India

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. MYLAN LABORATORIES LIMITED , HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

3 of section 32(1) and in support of his contention, he placed reliance upon the decision of the coordinate bench of the Tribunal in the case of AP Paper Mills Ltd., 128 TTJ 596 (Hyd.) and also the decision of the Hon’ble Delhi High Court in the case of Areva T&D India

COMM VAULT SYSTEMS (INDIA) PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYD, HYDERABAD

In the result, assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahm/S. Comm Vault Systems Vs Dy. Commissioner Of Income (India) Private Limited Tax, Circle 1(2) Hyderabad Hyderabad Pan: Aaccc 3708 L (Appellant) (Respondent)

depreciation on fixed assets, rental costs, postage charges, telecommunications and processing costs, electricity and maintenance expenses, legal and accounting fees and expenses, and other similar expenses. Such Operating Costs/Expenses shall be determined and apportioned on a basis consistent with that used internally by Distributor for similar costs and expenses. c) If Distributor's Operating Costs/Expenses exceed the sales revenue

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation. The Assessing Officer considered the revised claim of the Assessee under Section 80-IA and determined the amount eligible for deduction under Section 80-IA at Rs. 492,78,60,973/- against the NSL Renewable Power Pvt. Ltd., Hyd. Assessee’s claim of Rs. 546,26,01,224/-. However, the Assessing Officer stated in the assessment order that

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation. The Assessing Officer considered the revised claim of the Assessee under Section 80-IA and determined the amount eligible for deduction under Section 80-IA at Rs. 492,78,60,973/- against the NSL Renewable Power Pvt. Ltd., Hyd. Assessee’s claim of Rs. 546,26,01,224/-. However, the Assessing Officer stated in the assessment order that

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’).

depreciation involved was not verifiable. Therefore, if at all there is a mistake, then, it is in the quantification and carry forward of loss in AY 2005-06 because of the fact that loss could not have been carried forward due to delayed filing of return of income. However, once loss was quantified and allowed to be carried forward

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

depreciation accordingly. Hence, this ground of appeal is partly allowed. 15. The assessee challenged the order passed under section 250 with reference to section 143(3) r.w.s. 263 of the Income Tax Act 1961 by the ld.CIT(A) dt.27.05.2011 before the ITAT. The grounds of appeal raised by the assessee in the appeal under section 250 with reference to section

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

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

depreciation accordingly. Hence, this ground of appeal is partly allowed. 15. The assessee challenged the order passed under section 250 with reference to section 143(3) r.w.s. 263 of the Income Tax Act 1961 by the ld.CIT(A) dt.27.05.2011 before the ITAT. The grounds of appeal raised by the assessee in the appeal under section 250 with reference to section

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

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

depreciation accordingly. Hence, this ground of appeal is partly allowed. 15. The assessee challenged the order passed under section 250 with reference to section 143(3) r.w.s. 263 of the Income Tax Act 1961 by the ld.CIT(A) dt.27.05.2011 before the ITAT. The grounds of appeal raised by the assessee in the appeal under section 250 with reference to section

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

section 92CA(3) of the Act is bad in law, contrary to facts, law, and circumstances of the case and liable to be quashed for the following reasons: a) The order u/s 92CA(3) of the Act passed by the Ld. TPO is predated. b) The Ld. TPO erred by not issuing a show cause notice and further erred