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

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

24,450\nSeries A1 CCPS\n2018-19\n22,500\n22,500\nSeries A1 CCPS\nTotal\n94,207\n1,36,074\n2,30,281\n10.1.\nThe CCPS issued by the assessee are Compulsorily\nConvertible into equity shares on or before the initial public\noffer in the ratio of 1:1 at a conversion price which is\nequivalent to the price

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

24,450\n2018-19\n22,500\n22,500\nSeries A1 CCPS\nTotal\n94,207\n1,36,074 2,30,281\nSeries A1 CCPS\n10.1.\nThe CCPS issued by the assessee are Compulsorily\nConvertible into equity shares on or before the initial public\noffer in the ratio of 1:1 at a conversion price which is\nequivalent to the price

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

24,450\nSeries A1 CCPS\n2018-19\n22,500\n22,500\nSeries A1 CCPS\nTotal\n94,207\n1,36,074\n2,30,281\n10.1.\nThe CCPS issued by the assessee are Compulsorily\nConvertible into equity shares on or before the initial public\noffer in the ratio of 1:1 at a conversion price which is\nequivalent to the price

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NCL GREEN HABITATS PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

x) of clause (24) of section 2, if such income is not chargeable to income-tax under the head "Profits and gains of business or profession";] [(id) income by way of interest on securities, if the income is not chargeable to income-tax under the head "Profits and gains of business or profession";] (ii) income from machinery, plant or furniture

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:

24 February 2025 without considering the written submission filed by the Appellant on 21 February 2025, in response to the Issue letter, dated 12 February 2025 which had allowed the Appellant to furnish response within 10 days from the date of receipt of issue letter. 2. Non-grant of depreciation on goodwill on amalgamation a. The Ld. CIT has grossly

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. RAMKY ENERGY AND ENVIRONMENT LTD, HYDERABAD

In the result, both the appeals filed by the Revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

depreciation under section 32(1) (ii-a) of the Act. As per the settled position of law, an assessee claiming exemption has to strictly and literally comply with the exemption provisions. Therefore, the said decision shall not be applicable to the facts of the case on hand, while considering the exemption provisions. Even otherwise, Chapter III and Chapter

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3(1), HYDERABAD vs. RAMKY ENERGY AND ENVIRONMENT LIMITED, HYDERABAD

In the result, both the appeals filed by the Revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

depreciation under section 32(1) (ii-a) of the Act. As per the settled position of law, an assessee claiming exemption has to strictly and literally comply with the exemption provisions. Therefore, the said decision shall not be applicable to the facts of the case on hand, while considering the exemption provisions. Even otherwise, Chapter III and Chapter

PATHFINDER PUBLISHING PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE -16(2), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

section 56 shall be the value, on the valuation date, of such unquoted equity shares as determined in the following manner under clause (a) or clause (b), at the option of the assessee, namely:— (A-L) (a) the fair market value of unquoted equity shares = X (PV), (PE) where, A = book value of the assets in the balance-sheet

LYCOS INTERNET LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

24)(x) of the I.T. Act, 1961. In appeal, the learned CIT (A) has deleted the said addition by following various decisions of the Hon'ble High Courts wherein it was held that if the assessee has made the payment on or before the due date of filing the return of income u/s 139(1), then the same is allowable

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

X of the Act r.w. Explanation below section 80IA(8). After arriving at the market value / arm’s length price of goods or services, the profits and gains of eligible business / unit shall be computed by applying such value / price in respect of specified domestic transactions with non-eligible business / unit. Also, it is important to note that

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

x. Alleging the duplication of services, determining the arm's length of marketing and support services paid to DRL Russia at 50% of the total amount paid on ad-hoc basis. xi. erred in application of "the other method" without determining any arm's length price. 4 ITA.Nos.490 & 491/Hyd./2022 4. That on the facts and circumstances

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

x. Alleging the duplication of services, determining the arm's length of marketing and support services paid to DRL Russia at 50% of the total amount paid on ad-hoc basis. xi. erred in application of "the other method" without determining any arm's length price. 4 ITA.Nos.490 & 491/Hyd./2022 4. That on the facts and circumstances

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

depreciation claims as per law. 12. Next comes the sixth identical issue of section 14A r.w.r 8D disallowance issue of Rs.2,15,24,816/-, Rs.4,73,52,898/-, Rs.2,63,75,111/- and Rs.2,05,29,751/-; assessment year-wise; respectively. Suffice to say, we do not find any exempt income to have been derived in all these four years

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

depreciation claims as per law. 12. Next comes the sixth identical issue of section 14A r.w.r 8D disallowance issue of Rs.2,15,24,816/-, Rs.4,73,52,898/-, Rs.2,63,75,111/- and Rs.2,05,29,751/-; assessment year-wise; respectively. Suffice to say, we do not find any exempt income to have been derived in all these four years

VIVIMED LABS LIMITED,HYDERABAD vs. 500082 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

depreciation claims as per law. 12. Next comes the sixth identical issue of section 14A r.w.r 8D disallowance issue of Rs.2,15,24,816/-, Rs.4,73,52,898/-, Rs.2,63,75,111/- and Rs.2,05,29,751/-; assessment year-wise; respectively. Suffice to say, we do not find any exempt income to have been derived in all these four years

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX , HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

depreciation claims as per law. 12. Next comes the sixth identical issue of section 14A r.w.r 8D disallowance issue of Rs.2,15,24,816/-, Rs.4,73,52,898/-, Rs.2,63,75,111/- and Rs.2,05,29,751/-; assessment year-wise; respectively. Suffice to say, we do not find any exempt income to have been derived in all these four years

JAYA HOSPITALS,WARANGAL vs. ACIT, CIRCLE-1, WARANGAL

In the result, ITA No.616/Hyd/2022 is treated as allowed for statistical purposes and ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee on or before the due date. In other words, there is a marked distinction between the nature and character of the two amounts – the employer’s liability is to be paid

JAYA HOSPITALS,WARANGAL vs. ITO, WARD-1, WARANGAL

In the result, ITA No.616/Hyd/2022 is treated as allowed for statistical purposes and ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee on or before the due date. In other words, there is a marked distinction between the nature and character of the two amounts – the employer’s liability is to be paid