MYLAN LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result. appeal of the Assessee is partly\nallowed for statistical purposes and appeal of Revenue is\npartly allowed for statistical purposes

section 144C of the Income\nTax Act, 1961 on 31.12.2019 and determined the total\nincome of the appellant company at Rs.1446,55,55,275/- by\nmaking TP adjustment as suggested by the TPO under\nsection 92CA(3) of the Act for Rs.1191,97,64,708/-,\ndisallowance of depreciation

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)

64,773 to the international transaction pertaining to provision of software development and support services. 4. On the facts and in the circumstances of the case and in law, the Ld. DRP / Ld. TPO / Ld. AO erred in rejecting the TP documentation maintained by the Appellant, in good faith, as required under section 92D of the Act read with rule

UNICON INDUSTRIES PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-17(2) , HYDERABAD

Appeal is allowed in above terms

Bench: Shri A. Mohan Alankamony & Shri S.S. Godaraassessment Year: 2014-15 M/S. Unicorn Industries Vs. The Deputy Commissioner Pvt. Ltd., Of Income Tax, Hyderabad – 500003. Circle 17(2), Pan : Aaacu3501D. Hyderabad. (Appellant) (Respondent) Assessee By: Sri A.V. Raghuram Revenue By: Sri T. Sunil Goutam Date Of Hearing: 06/12/2021 Date Of Pronouncement: 07/12/2021 O R D E R Per S. S. Godara, J.M. This Assessee’S Appeal For A.Y 2014-15 Arises From The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi’S Order Dated 21.09.2021 In Case No.Itba/ Nfac/S/250/2021-22/1035761358(1) Involving Proceedings Under Section 250 Of Income Tax Act, 1961 (In Short, “The Act”).

section 250 of Income Tax Act, 1961 (in short, “the Act”). Heard both the parties. Case file perused. 3. Coming to the assessee’s sole substantive grievance that both the lower authorities have erred in law and on facts in disallowing its depreciation relief of Rs.7,64

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

64,97,030 Riunite Cemento SpA Similarly for A.Y. 2013-14 which are forming part of Para 4 of the TPO order to the following effect : International Transactions Name of the Associated Nature of Transaction Amount (Rs) Enterprises Ciment Francias SA Technical knowhow and research 14,38,61,822 and other service fees Ciment Francias SA Sub-license

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

64,97,030 Riunite Cemento SpA Similarly for A.Y. 2013-14 which are forming part of Para 4 of the TPO order to the following effect : International Transactions Name of the Associated Nature of Transaction Amount (Rs) Enterprises Ciment Francias SA Technical knowhow and research 14,38,61,822 and other service fees Ciment Francias SA Sub-license

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

64,97,030 Riunite Cemento SpA Similarly for A.Y. 2013-14 which are forming part of Para 4 of the TPO order to the following effect : International Transactions Name of the Associated Nature of Transaction Amount (Rs) Enterprises Ciment Francias SA Technical knowhow and research 14,38,61,822 and other service fees Ciment Francias SA Sub-license

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

64,97,030 Riunite Cemento SpA Similarly for A.Y. 2013-14 which are forming part of Para 4 of the TPO order to the following effect : International Transactions Name of the Associated Nature of Transaction Amount (Rs) Enterprises Ciment Francias SA Technical knowhow and research 14,38,61,822 and other service fees Ciment Francias SA Sub-license

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

64,97,030 Riunite Cemento SpA Similarly for A.Y. 2013-14 which are forming part of Para 4 of the TPO order to the following effect : International Transactions Name of the Associated Nature of Transaction Amount (Rs) Enterprises Ciment Francias SA Technical knowhow and research 14,38,61,822 and other service fees Ciment Francias SA Sub-license

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

64 31-32 of PB) Form 10CCB for eligible units claiming 80-IA deduction (refer Page 65 to 76 35 to 46 of PB) The Assessee submits that the deduction computed u/s. 80-IA of the Act should be allowed in totality from the GTI and should not to be restricted ONLY to Income from Business or Profession. In support

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

64 31-32 of PB) Form 10CCB for eligible units claiming 80-IA deduction (refer Page 65 to 76 35 to 46 of PB) The Assessee submits that the deduction computed u/s. 80-IA of the Act should be allowed in totality from the GTI and should not to be restricted ONLY to Income from Business or Profession. In support

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

OCEAN SPARKLE LIMITED,HYDERABAD vs. DCIT., CIRCLE 5(1), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

64,564/-, disallowance of forex gain of Rs.1,39,93,231/- as against the returned income of the 5 ITA.No.1030/Hyd./2024 assessee at Rs.12,29,39,428/- vide order dated 30.06.2015 u/sec.143(3) r.w.s.263 of the Income Tax Act, 1961. 4. Aggrieved by the order of the Assessing Officer passed in pursuance to the directions of the learned PCIT

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. MAGNA HOMES, HYDERABAD

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2018-19 The Deputy Commissioner Of Vs. M/S. Magna Homes, Hyderabad. Income Tax, Central Circle 3(1), Pan : Aapfg5917K Hyderabad. (Appellant) (Respondent) Assessee By: Shri Ravi Bharadwaj Revenue By: Dr. Sachin Kumar, Sr.D.R. Date Of Hearing: 08.01.2025 11.02.2025 Date Of Pronouncement:

section 148A(b) was issued to the appellant on 16.03.2022 and in response, the appellant has 3 ITA 327/Hyd/2024 not furnished any information. Order u/s. 148A(d) was passed with the prior approval of the specified authority. Accordingly, notice u/s. 148 of the Act was issued to the appellant on 30.03.2022. However, the appellant has not filed any return

DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD vs. GLOBAL ALUMINIUM PVT. LTD., SECUNDERABAD, SECUNDERABAD

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

64,61,700/- and Rs.3,49,81,040/-; assessment year wise, respectively, made in the course of corresponding assessments. Both the learned representatives lead us to CIT(A)’s lead findings to this effect in first and foremost AY 2012-13 reading as under. “4. The ground no.1,8 and 9 are general in nature which do not require specific

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

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

64,61,700/- and Rs.3,49,81,040/-; assessment year wise, respectively, made in the course of corresponding assessments. Both the learned representatives lead us to CIT(A)’s lead findings to this effect in first and foremost AY 2012-13 reading as under. “4. The ground no.1,8 and 9 are general in nature which do not require specific

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD vs. GLOBAL ALUMINIUM PRIVATE LIMITED, SECUNDERABAD

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

64,61,700/- and Rs.3,49,81,040/-; assessment year wise, respectively, made in the course of corresponding assessments. Both the learned representatives lead us to CIT(A)’s lead findings to this effect in first and foremost AY 2012-13 reading as under. “4. The ground no.1,8 and 9 are general in nature which do not require specific

INCOME TAX OFFICER, WARD-2(2), HYDERABAD vs. GLOBAL ALUMINIUM PRIVATE LIMITED , HYDERABAD

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

64,61,700/- and Rs.3,49,81,040/-; assessment year wise, respectively, made in the course of corresponding assessments. Both the learned representatives lead us to CIT(A)’s lead findings to this effect in first and foremost AY 2012-13 reading as under. “4. The ground no.1,8 and 9 are general in nature which do not require specific

PREMIER POULTRY PRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

Bench: Us:

Section 143(3) r.w.s. 263 of the Income Tax Act, 1961 (for short “the Act”) dated 30.03.2022 for A.Y. 2015-16. The assessee company has assailed the impugned order on the following grounds of appeal before us: “1. The learned Commissioner of Income Tax (Appeals) erred in facts and law while passing disposing the appeal. 2. The learned Commissioner