VERMEIREN INDIA REHAB PRIVATE LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

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

Bench: Shri Manjunatha G & Shri Ravish Sood

208. Ground No. 2: Corporate Tax: Denial of Depreciation 2.1. In law and facts and circumstances of the case, the Ld. AO/DRP have erred in denying the depreciation claimed by the Assessee on the following grounds: 2.1.1. That the Ld. AO/DRP erred in not granting depreciation on building under section

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

208/-; (iv) disallowance towards TDS and VAT payable under section 43B of the Act: Rs. 6,08,694/-; and (v) addition of Rs.3,34,246/- on account of estimated profit on undisclosed sales: Rs.3,34,246/-, but at the same time declined the assessee’s claim regarding the validity of jurisdiction that was assumed by the AO, while initiating proceedings

SIGNODE INDIA LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

208. Ground No. 2: Corporate Tax: Denial of Depreciation 2.1. In law and facts and circumstances of the case, the Ld. AO/DRP have erred in denying the depreciation claimed by the Assessee on the following grounds: 2.1.1. That the Ld. AO/DRP erred in not granting depreciation on building under section

SIGNODE INDIA LIMITED,HYDERABAD vs. ACIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

208. Ground No. 2: Corporate Tax: Denial of Depreciation 2.1. In law and facts and circumstances of the case, the Ld. AO/DRP have erred in denying the depreciation claimed by the Assessee on the following grounds: 2.1.1. That the Ld. AO/DRP erred in not granting depreciation on building under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

208 ITR 989 in which it was held that deduction under section 36(1)(iii) can only be allowed on the interest if the assessee borrows capital for its own business. Hence, it was held that interest on the borrowed amount could not be allowed if such amount had been advanced to a subsidiary company of the assessee. With respect

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

208 ITR 989 in which it was held that deduction under section 36(1)(iii) can only be allowed on the interest if the assessee borrows capital for its own business. Hence, it was held that interest on the borrowed amount could not be allowed if such amount had been advanced to a subsidiary company of the assessee. With respect

DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

208 ITR 989 in which it was held that deduction under section 36(1)(iii) can only be allowed on the interest if the assessee borrows capital for its own business. Hence, it was held that interest on the borrowed amount could not be allowed if such amount had been advanced to a subsidiary company of the assessee. With respect

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED., HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

208 ITR 989 in which it was held that deduction under section 36(1)(iii) can only be allowed on the interest if the assessee borrows capital for its own business. Hence, it was held that interest on the borrowed amount could not be allowed if such amount had been advanced to a subsidiary company of the assessee. With respect

DCIT, CIRCLE-17(1), HYD, HYDERABAD vs. ECI ENGINEERING & CONSTRUCTION CO. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

208/- on account of disallowance u/s 40(a)(ia) of the Act. Thus, the income of the assessee was computed at Rs.8.43,96,302/-. In the assessment order, the Assessing Officer in para 4 has mentioned as under : “4. It is noticed from the Annexure-13 to the Tax Audit Report submitted during the course of assessment proceedings, there

ECI ENGINEERING & CONSTRUCTION COMPANY LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-2(2), HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

208/- on account of disallowance u/s 40(a)(ia) of the Act. Thus, the income of the assessee was computed at Rs.8.43,96,302/-. In the assessment order, the Assessing Officer in para 4 has mentioned as under : “4. It is noticed from the Annexure-13 to the Tax Audit Report submitted during the course of assessment proceedings, there

SKANDA BUILDERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

Sections 132(4A) and\n292C of the Income Tax Act create a rebuttable presumption that documents\nfound during a search belong to the assessee and are true. Courts have\nconsistently held that selective reliance on seized material is unjustified\nunless the contents are independently proved against the\n\nITA.Nos.514 to 539/Hyd./2025,\nAnd ITA.Nos.308 to 311/Hyd./2025

SAI LIFE SCIENCES LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

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

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2017-18 M/S.Sai Life Sciences Ltd Vs. Dy. C. I. T. Hyderabad Circle 3(1) Pan:Aaecs6143F Hyderabad (Appellant) (Respondent) Assessee By: Shri Ashik Shah, Ca Revenue By: Smt. Sheetal Sarin, Cit(Dr)

section 2(3) of the Motor Vehicles Act, 1988 is a deeming provision that creates a legal fiction of ownership in favour of lessee only for the purpose of Motor Vehicles Act. Page 3 of 10 ITA No 134 of 2023 Sai Life Sciences Ltd 9. Referring to page 250 of the Paper Book, the learned Counsel for the assessee

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. BLEND COLOURS PRIVATE LIMITED , HYDERABAD

In the result, the appeal of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2015-16 Blend Colours Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 1(2), Pan – Aaccb 2492 A Hyderabad. (Appellant) (Respondent) Assessment Year: 2015-16 Dy. Commissioner Of Vs Blend Colours Pvt. Ltd., Income-Tax, Hyderabad. Circle – 1(2), Hyderabad. Pan – Aaccb 2492 A (Appellant) (Respondent) Assessee By: Shri Sidharth Toshnival Revenue By: Shri A. Sitarama Rao Date Of Hearing: 05/07/2021 Date Of Pronouncement: 22/07/2021

section 115JB. Subsequently, the case was taken up for limited scrutiny under CASS and notices u/s 143(2) and 142(1) were issued and duly served on the assessee. In responses to the notices, the AR of the assessee furnished the details. 2.1 During the scrutiny proceedings, on perusal of P & L Account, the AO noticed that under the head

BLEND COLOURS PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, the appeal of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2015-16 Blend Colours Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 1(2), Pan – Aaccb 2492 A Hyderabad. (Appellant) (Respondent) Assessment Year: 2015-16 Dy. Commissioner Of Vs Blend Colours Pvt. Ltd., Income-Tax, Hyderabad. Circle – 1(2), Hyderabad. Pan – Aaccb 2492 A (Appellant) (Respondent) Assessee By: Shri Sidharth Toshnival Revenue By: Shri A. Sitarama Rao Date Of Hearing: 05/07/2021 Date Of Pronouncement: 22/07/2021

section 115JB. Subsequently, the case was taken up for limited scrutiny under CASS and notices u/s 143(2) and 142(1) were issued and duly served on the assessee. In responses to the notices, the AR of the assessee furnished the details. 2.1 During the scrutiny proceedings, on perusal of P & L Account, the AO noticed that under the head