VK WAREHOUSING ENTERPRISES,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

depreciation: Rs. 3,11,24,473/-; (iii) disallowance under Section 40(a)(ia) of the Act: Rs. 32,89,736/-; (iv) disallowance of interest on delayed remittance of TDS: Rs.1,37,887/-; and (v) addition of unexplained cash deposits u/s 68 of the Act: Rs. 25,85,800/-. Accordingly, the AO, vide his order passed under Section 144

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

144 by the Learned CIT(OR) and non- fulfilment of ownership criteria for the purpose of claiming depreciation under section

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

144 by the Learned CIT(OR) and non- fulfilment of ownership criteria for the purpose of claiming depreciation under section

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

144 by the Learned CIT(OR) and non- fulfilment of ownership criteria for the purpose of claiming depreciation under section

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

144 by the Learned CIT(OR) and non- fulfilment of ownership criteria for the purpose of claiming depreciation under section

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

144 by the Learned CIT(OR) and non- fulfilment of ownership criteria for the purpose of claiming depreciation under section

LAXMI VENKATA KRISHNA RICE CORPORATION,NALGONDA vs. ITO, WARD-1, SURYAPET

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

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

depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment

SANJEEV KUMAR NALAM,HYDERABAD vs. ITO, WARD-1, NIRMAL

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.669/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Sanjeev Kumar Nalam Vs. Income Tax Officer Hyderabad Ward – 1 Pan:Avdpn0497L Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment

ACIT., CIRCLE-6(1), HYDERABAD vs. VK WAREHOUSING ENTERPRISES, HYDERABAD

In the result, both the appeals filed by the assessee firm and

depreciation: Rs. 3,11,24,473/-; (iii) disallowance under Section 40(a)(ia) of the Act: Rs. 32,89,736/-; (iv) disallowance of interest on delayed remittance of TDS: Rs.1,37,887/-; and (v) addition of unexplained cash deposits u/s 68 of the Act: Rs. 25,85,800/-. Accordingly, the AO, vide his order passed under Section 144

INCOME TAX OFFICER, WARD-1, NELLORE vs. VENKATA RAMANAMMA SAKAMURI, NELLORE

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

Bench: Us:

depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment

THULASI CHAMARTHY,CHITTOOR vs. INCOME TAX OFFICER, WARD - 1, CHITTOOR

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

depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-9(1), HYDERABAD vs. VINSRI INFOTECH, HYDERABAD

In the result, assessee’s appeal is partly allowed and the revenue’s appeal is dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyblock Period: 1996-97 To 2001-2002 M/S Vinsri Infotech, Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 9(1), Hyderabad. Pan – Aabfv6806E Appellant Respondent & Block Period: 1996-97 To 2001-2002 Dy. Commissioner Of Vs. M/S Vinsri Infotech, Income-Tax, Circle – Hyderabad. 9(1), Hyderabad Pan – Aabfv 6806 E Appellant Respondent Assessee By: Shri Y. Ratnakar Revenue By: Shri Sunku Srinivasu Date Of Hearing: 19/09/2019 Date Of Pronouncement: 04/12/2019 O R D E R Per P. Madhavi Devi, J.M.:

144 on 30-01-05 for failure to comply with notices under Section 158BC and 142(1) of the Income Tax Act, raising a tax and interest demand of Rs.2,66,22,170/-. Soon after his release Sri C.Suresh, GPA Holder represented under Section 264 of the IT Act before the Commissioner of Income tax, Central Circle, for grant

M/S VINSRI INFOTECH,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-9(1), HYDERABAD

In the result, assessee’s appeal is partly allowed and the revenue’s appeal is dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyblock Period: 1996-97 To 2001-2002 M/S Vinsri Infotech, Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 9(1), Hyderabad. Pan – Aabfv6806E Appellant Respondent & Block Period: 1996-97 To 2001-2002 Dy. Commissioner Of Vs. M/S Vinsri Infotech, Income-Tax, Circle – Hyderabad. 9(1), Hyderabad Pan – Aabfv 6806 E Appellant Respondent Assessee By: Shri Y. Ratnakar Revenue By: Shri Sunku Srinivasu Date Of Hearing: 19/09/2019 Date Of Pronouncement: 04/12/2019 O R D E R Per P. Madhavi Devi, J.M.:

144 on 30-01-05 for failure to comply with notices under Section 158BC and 142(1) of the Income Tax Act, raising a tax and interest demand of Rs.2,66,22,170/-. Soon after his release Sri C.Suresh, GPA Holder represented under Section 264 of the IT Act before the Commissioner of Income tax, Central Circle, for grant

SUKESINI KUMILI,HYDERABAD vs. ITO, WARD-15(1), HYDERABAD

In the result, the appeals of the assessee in ITA no

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaappeal In Ita Nos. Assessee Revenue A.Ys 1536 To 1539/ Hyd/2025 Sukesini Kumili, Hyderabad Pan:Ckmpk5466J Income Tax Officer Ward 15(1), Hyderabad 2015-16 & 2016-17 निर्धारिती द्वारा /Assessee By: Advocate Shri S. Rama Rao राजस्व द्वारा / Revenue By:: || Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: | 07/01/2016 घोषणा की तारीख / Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili ("The Assessee") Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

144 and 144B of the Act are bad in law and liable to be quashed. 5. Per contra, the Ld. DR strongly supported the orders of the lower authorities. He submitted that the legal issue raised by the assessee is pending adjudication before the Hon'ble Supreme Court in the case of Hexaware Technology Ltd., in the SLP filed

SUDHEER PARIMALA,HYDERABAD vs. INCOME TAX OFFICER, WARD-10(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.758/Hyd./2025 Assessment Year 2015-2016 Sudheer Parimala, The Income Tax Officer, Hyderabad – 500 016. Vs. Ward-10(1), Hyderabad. Pan Ahppp7572E Pin - 500 004. Telangana (Appellant) (Respondent) For Assessee : Ca Kranthi Palivela & Ca Mrudulatha For Revenue : Dr. Sachin Kumar, Sr. Ar Date Of Hearing : 24.03.2026 Date Of Pronouncement : 17.04.2026 आदेश/Order

depreciation claimed by the assessee amounting to Rs. 78,26,412 is still stand unexplained with proper evidence." 19. The Revenue has not disclosed as to whether the proceedings under Section 154 of the Act had ended up in passing of an order. Even then, the reopening of assessment proceedings under Section 148 of the Act would amount

GMR HOSPITALITY AND RETAIL LIMITED (SUCCESSOR TO HYDERABAD DUTY FREE RETAIL LIMITED),HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri A. Mohan Alankamony & Shri S.S. Godaraa.Y. 2016-17 Gmr Hospitality & Retail Vs. Income Tax Officer, Limited (Successor Of Ward-2(2), Hyderabad Duty Free Retail Hyderabad. Limited), Hyderabad. Pan: Aadcg 2928 F (Appellant) (Respondent) Assessee By Shri Sunil Jain, Ar Revenue By Smt. M. Narmada, Dr Date Of Hearing: 02/09/2021 Date Of Pronouncement: 16/09/2021 Order

144." 13. As stated above, one of the main arguments advanced by the learned Additional Solicitor General on behalf of the Department before us was that the word "expenditure" in section 37(1) connotes "what is paid out" and that which has gone irretrievably. In this connection, heavy reliance was placed on the judgment of this Court in the case

PRIMARY AGRICULTURAL CO OP CREDIT SOCIETY LIMITED MINARPALLY,MINARPALLY VILLAGE vs. INCOME TAX OFFICER, WARD-1, NIZAMABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.140/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2016-17) Primary Agricultural Vs. Income Tax Officer Cooperative Credit Society Ward 1 Ltd Minarpally, Minarpally Minarpally, Nizamabad Pan:Aabap7760J (Respondent) (Appellant) निर्धारिती द्वारा / Assessee By: C.A Akshay Surana राजस्व द्वारा / Revenue By:: Smt. Helen Ruby Jesindha, Sr. Dr सुनवाई की तारीख / Date Of Hearing: 22/12/2025 घोषणा की तारीख / Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Primary Agricultural Cooperative Credit Society Ltd Minarpally (“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 05.11.2024 For The A.Y, 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal: Page 1 Of 18

144 and 144B of the Act are bad in law and liable to be quashed. 7. Per contra, the Ld. DR relied on the order of the lower authorities. In alternate submission, the Ld. DR submitted that the issue is pending adjudication before the Hon'ble Supreme Court, and therefore the issue may be kept open until decided

VITP PRIVATE LIMITED (IN THE CASE OF FLAGSHIP DEVELOPERS PRIVATE LIMITED),HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.572/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Vitp Private Ltd (In The Vs. Dy. Commissioner Of Case Of Flagship Income Tax, Circle 8(1) Developers (P) (Ltd) Hyderabad Hyderabad Pan:Aaccv2672G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Tanmayee Rajkumar राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 20/11/2024 घोषणा की तारीख/Pronouncement: 02/01/2025 आदेश/Order

144 (Rs 176001521-127186377) as per books and any other reason if found. In this regard, we wish to submit that in the Return of income filed u/s 139(1) of the Act in the case of FDPL under PAN: AAACF9235B. book depreciation of INR 24,04,18,433 was claimed as deduction in the computation of book profit

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