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

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

section 143(3) r/w 153A on 31.03.2013 for the A.Y. 2005-06 and 2006-07. However, in both the orders, the Assessing Officer has not given any deduction claimed by the assessee. In the assessment order dt.31.03.2013 mentioned as under : “Search and seizure operations u/s. 132 of the I.T. Act, 1961 were carried out in the case of M/.s. Madhucon

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

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

section 143(3) r/w 153A on 31.03.2013 for the A.Y. 2005-06 and 2006-07. However, in both the orders, the Assessing Officer has not given any deduction claimed by the assessee. In the assessment order dt.31.03.2013 mentioned as under : “Search and seizure operations u/s. 132 of the I.T. Act, 1961 were carried out in the case of M/.s. Madhucon

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

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

section 143(3) r/w 153A on 31.03.2013 for the A.Y. 2005-06 and 2006-07. However, in both the orders, the Assessing Officer has not given any deduction claimed by the assessee. In the assessment order dt.31.03.2013 mentioned as under : “Search and seizure operations u/s. 132 of the I.T. Act, 1961 were carried out in the case of M/.s. Madhucon

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)

ii) On the facts and in the circumstances of the case and in law, the final assessment order dated 13 June 2024 under section 143(3) read with section 144C(13) of the Act passed by Assessment Unit, Income-tax Department, pursuant to invalid directions passed by Hon'ble DRP, is illegal; thus making the final assessment order

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

ii). he must also have a reason to believe\nthat such escapement had occurred by reason of failure on the part of\nthe assessee for either of the two conditions, viz. (a). to make a return\nof income under Section 139 or in response to notice issued under sub-\nsection (1) of Section 142 or Section

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

depreciation under Section 32(ia), without revising the\nopening WDV of plant and machinery on account of the amount of\ndepreciation disallowed in the previous year.\nInvestment allowance under Section 32AD\n8. On the facts and circumstances of the case and in law, the Id. AO,\nunder the direction of the Hon'ble DRP, erred in not appreciating\nthat

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

ii) no loss referred to in sub-section (1) of section 72 or sub- section (1) or sub-section (3) of section 74, in so far as such loss relates to the business of the undertaking, shall be carried forward or set off where such loss relates to any of the relevant assessment years 16[ending before

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)

Depreciation adjustment 14. Without prejudice to argument in Ground 6, the expenses disallowed under 40(a) (i) of the Act should also be excluded from the cost base of the Appellant while computing the operating margin and transfer pricing adjustment.” 2. Also, the assessee company has raised the following additional ground of appeal, which reads as under: “Ground No.15

ACIT, CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

depreciation on film software library was also set aside for further examination. The Tribunal also dealt with issues related to disallowance under Section 14A and subscription revenue.", "result": "Partly Allowed", "sections": [ "147", "148", "143(3)", "32(1)(ii

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:

143(3) of the Act on 20.12.2017 making an addition of Rs.1,17,93,630/- on account of disallowance under section 14A of the Act, while allowing the claim of the assessee on account of depreciation on non-compete fees and depreciation on royalty amounting to Rs.3,74,68,790/- and Rs.75,34,379/- respectively, and assessed the total income

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. ABIR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the revenue is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Asst. Commissioner Of Vs. Abir Infrastructure Pvt. Income-Tax, Ltd., Hyderabad. Central Circle – 1(3), Hyderabad. Pan – Aafc3608N (Appellant) (Respondent)

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned(hereinafter in this section and in sections 148 to 153 referred to as the relevant assessmen t year): Provided that where an assessment under sub- section(3) of section 143 or this section has been made for the relevant assessment year, no action shall

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

depreciation but directed re-examination of valuation. The Tribunal also set aside the order on Section 14A disallowance for further examination by the AO.", "result": "Partly Allowed", "sections": [ "147", "148", "143(3)", "32(1)(ii

ACIT., CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

depreciation. The appeals concerning marketing expenses and subscription revenue were remitted back to the Assessing Officer for further verification.", "result": "Partly Allowed", "sections": [ "14A", "32(1)(ii)", "142A", "143(3

PENNAR INDUSTRIES LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1),, HYDERABAD

In the result, the appeal filed by the assessee company is partly allowed/partly allowed for statistical purposes

Bench: Us:

143(3) r.w.s. 144B of the Act, dated 20.09.2022, the Ld. AR submitted that the AO vide his notice u/s 142(1) of the Act, dated 20/02/2022, had specifically directed the assessee company to furnish complete details of the debts that were written off during the year under consideration, i.e., details of the debts alongwith names, PAN, amount of interest

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

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

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

3(b) read with section 32(I)(ii) of the Income-tax Act, 1961 ('Act') and thus the Guruvayoor Infrastructure Pvt. Ltd., Hyd. assessee is eligible to claim depreciation on such asset at the specified rate (i.e., 25%), does not lay the correct law on the issue of depreciation on toll roads as it has not considered the ruling

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED , HYDERABAD

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

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

3(b) read with section 32(I)(ii) of the Income-tax Act, 1961 ('Act') and thus the Guruvayoor Infrastructure Pvt. Ltd., Hyd. assessee is eligible to claim depreciation on such asset at the specified rate (i.e., 25%), does not lay the correct law on the issue of depreciation on toll roads as it has not considered the ruling

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED , HYDERABAD

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

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

3(b) read with section 32(I)(ii) of the Income-tax Act, 1961 ('Act') and thus the Guruvayoor Infrastructure Pvt. Ltd., Hyd. assessee is eligible to claim depreciation on such asset at the specified rate (i.e., 25%), does not lay the correct law on the issue of depreciation on toll roads as it has not considered the ruling

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVAT LIMITED, HYDERABAD

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

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

3(b) read with section 32(I)(ii) of the Income-tax Act, 1961 ('Act') and thus the Guruvayoor Infrastructure Pvt. Ltd., Hyd. assessee is eligible to claim depreciation on such asset at the specified rate (i.e., 25%), does not lay the correct law on the issue of depreciation on toll roads as it has not considered the ruling