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(iia) ought to be\ngranted is 35 per cent and not 20 per cent.\nInvestment allowance under Section 32AC\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 the Appellant ought to be granted investment allowance

SSNC FINTECH SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

270A r.w.s. 274 of the Act.\n3:2.\nThe Appellant craves leave to add, alter,\namend and/or substitute and/or modify in any manner\nwhatsoever modify all or any of the foregoing grounds of\nappeal at or before the hearing of the appeal.”\nBriefly stated facts of the case are that, the\nappellant-company viz., SSNC Fin Tech Services India Private

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

depreciable asset as per\nthe proviso to section 43 of the Act, which the AO has\nomitted.\n19.\nWe have heard rival submissions on the\nissue in dispute and perused the material on record.\nWe find that computation of LTCG on the transfer of\nundertaking as the slump sale consists of two\ncomponents. First component is sale consideration\nand

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

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

depreciable asset as per\nthe proviso to section 43 of the Act, which the AO has\nomitted.\n19.\nWe have heard rival submissions on the\nissue in dispute and perused the material on record.\nWe find that computation of LTCG on the transfer of\nundertaking as the slump sale consists of two\ncomponents. First component is sale consideration\nand

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

depreciable asset as per\nthe proviso to section 43 of the Act, which the AO has\nomitted.\n19.\nWe have heard rival submissions on the\nissue in dispute and perused the material on record.\nWe find that computation of LTCG on the transfer of\nundertaking as the slump sale consists of two\ncomponents. First component is sale consideration\nand

ASCENTECH ENGINEERING SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Depreciation\n0.00\n10:00\n10.00\n10:00\n10:00\nLess Additions to Fixed Assets\n50.00\n50.00\n10.00\n10.00\nNet Free Cash Flow\n120.00\n-82.00\n-2.00\n30.75\n47.46\nNPV Discount Factor @\n18%\n0.8510724\n0.743\n0.616\n0.525\n0.446\nNPV Value of Free Cash Flow of future years\n102.1359.301.23\n16.13\n21.19\nCumulative Value of Free Cash Flo\n102.13\n-16152\n162.75-146.62

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

depreciation and interest amounts can be compared they are not at al near to projections, there is huge variation to projections and actual. Further, in the valuati9on report, the average share value was arrived by taking the share valued as per DOE method, Book Value Method and Market value of properties, but, in the same valuation report it failed

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)

270A and 271AA, without considering the fact that the aforesaid transfer pricing adjustment is on account of difference of opinion. 5 Gainsight Software Private Limited The Appellant craves leave to add to, alter, omit or substitute any or all of the above grounds of appeal or produce further documents at any time before or at the time of the appeal

TEK SYSTEMS GLOBAL SERVICES PRIVATE LIMITED,HYDERBAD vs. DCIT, CIRCLE-2(1), HYDERBAD

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

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.487/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2018-19) Tek Systems Global Vs. Dy. C. I. T. Services (P) Ltd, Circle 2(1) Hyderabad Hyderabad Pan:Aabcf1518Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms. K. Amulya, Ca रधजस् व द्वधरध/Revenue By:: Shri Jeevan Lal Lavidiya, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 29/05/2024 घोर्णध की तधरीख/Pronouncement: 05/07/2024 आदेश/Order

270A are initiated for under reporting of income. Accordingly, the income is computed as under: Returned income as per revised return - Rs.24,18,41,090/- Add. TPO Adjustment - Rs.5,88,22,320/- Education Cess disallowed - Rs. 23,85,335/- Depreciation disallowed - Rs. 33,46,509/- Total - Rs.30,57,95,254/- 7. Aggrieved with such order of the learned

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:

270A. The appellant challenged the procedural lapses, including non- compliance with Sections 148A(b), 149, and 151, and seeks relief on these grounds. Reliance is placed on relevant case law, including the decision in Kankanala Ravindra Reddy v. ITO, favoring procedural adherence. The appellant requests a condonation of delay in filing the appeal, citing health and mental distress

ASSISTANT COMMISSIONER OF INCOME TAX ,CIRCLE-1(1) , TIRUPATI vs. VENKATA SWAMY RAVURI , CHITTOOR

In the result, the appeal of the Revenue is allowed for\nstatistical purposes

section 2(1A) makes it clear that it is necessary that the land\nshould be hold and it should be utilized for agriculture purposes, once\nthese two criteria are fulfilled the revenue earned from such activity can\ncategorized as \"agricultural income\". In this regard, the appellant has\nfurnished both the data and hence the income has to be categorized

ALTIUX INNOVATIONS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1006 To 1008/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Altiux Innovations (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 1(1) Pan: Aalca9069R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sai Sarikonda, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Pronouncement: 16/01/2025 आदेश/Order

270A and penalty order passed u/s 271AAC(1) of the I.T. Act, 1961 respectively for the A.Y.2020-21. Page 1 of 8 ITA Nos 1006 to 1008 of 2024 Altiux Innovations P Ltd 2. In the quantum appeal, the assessee has raised the following grounds of appeal: “1. The Ld CIT (A) erred both in the circumstances of the case

ALTIUX INNOVATIONS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1006 To 1008/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Altiux Innovations (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 1(1) Pan: Aalca9069R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sai Sarikonda, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Pronouncement: 16/01/2025 आदेश/Order

270A and penalty order passed u/s 271AAC(1) of the I.T. Act, 1961 respectively for the A.Y.2020-21. Page 1 of 8 ITA Nos 1006 to 1008 of 2024 Altiux Innovations P Ltd 2. In the quantum appeal, the assessee has raised the following grounds of appeal: “1. The Ld CIT (A) erred both in the circumstances of the case

ALTIUX INNOVATIONS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1 (1), HYDERABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1006 To 1008/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Altiux Innovations (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 1(1) Pan: Aalca9069R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sai Sarikonda, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Pronouncement: 16/01/2025 आदेश/Order

270A and penalty order passed u/s 271AAC(1) of the I.T. Act, 1961 respectively for the A.Y.2020-21. Page 1 of 8 ITA Nos 1006 to 1008 of 2024 Altiux Innovations P Ltd 2. In the quantum appeal, the assessee has raised the following grounds of appeal: “1. The Ld CIT (A) erred both in the circumstances of the case

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

depreciation of earlier assessment years. 9. That in the facts and circumstances of the case, the Ld. AO is not justified in considering short credit of TDS to the tune of Rs. 30,211/- without assigning any reasons therefor. 10. The appellant craves leave to add, amend or alter any of the grounds during the course of hearing.” 2. Brief

AUROBINDO PHARMA LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.172/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2019-20) Aurobindo Pharma Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aabca7366H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri B.G. Reddy, Advocate राज" व "ारा/Revenue By:: Smt. M Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/01/2025 घोषणा की तारीख/Pronouncement: 19/02/2025 आदेश/Order

depreciation amounting to Rs. 27,19,777/- Page 3 of 18 ITA No 172 of 2023 Aurobindo Pharma Ltd despite directions by the Honourable DRP in this regard allowing the same as eligible expenditure. General 1. Any other ground that may be urged at the time of hearing with the previous approval of the Hon'ble Tribunal.” 3. Ground Nos.1

KARIMNAGAR MILK PRODUCER COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE-1, KARIMNAGAR

Depreciation, Interest and Tax (PBDIT) was in the\n\nrange of 0.14% to 0.37%. It was further observed by him that the\nassessee company had during the subject year disclosed PBDIT of\n0.16%. Considering the above, the A.O. estimated the income of the\nassessee company at 1.5% of its total turnover of Rs.249.46 Crores\n(supra) which worked

DAICEL CHIRAL TECHNOLOGIES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2017-18 M/S. Daicel Chiral Vs. 1. Deputy Technologies India Private Commissioner Of Limited, Income Tax, Circle Medchal, 8(1), Hyderabad. Hyderabad. 2. National Faceless Pan : Aaccd8423B. Assessment Centre, Delhi. (Appellant) (Respondent) Assessee By: Shri N. Pradeep Revenue By: Shri T. Vijaya Bhaskar Reddy Date Of Hearing: 01.02.2023 Date Of Pronouncement: 03.02.2023 O R D E R Per Laliet Kumar, J.M.

section 4 and 10 of the Act is that given its ordinary and natural meaning. The word income we take in any monetary return come in. The work income is of the widest amplitude and must be given its natural and grammatical meaning —CIT v G R Karthikeyan( 1993) 201 ITR 866 874(SC). Income is taxable when it accuses