MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

Deemed. Dividend. 5. The Ld.CIT(A) erred in appreciating the fact that the outstanding debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact loan/advance which attracts the provisions of section 2(22)(e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of drugs

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

Deemed. Dividend. 5. The Ld.CIT(A) erred in appreciating the fact that the outstanding debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact loan/advance which attracts the provisions of section 2(22)(e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of drugs

INDUKURI SUNDARI, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeals of both assessee’s are allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blesmt Indukuri Sundari V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aakpi8049P (Appellant) (Respondent) Shri Indukuri Syam Prasad Reddy V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aadpi1621C (Appellant) (Respondent) : Shri Mohammad Afzal Assessee By Department By : Shri M.V.S.T. Sai

deemed dividend u/s 2(22)(e). However, while according his approval in terms with section 153D, Addl. CIT, who is range head directed Assessing Officer not to make addition u/s 2(22)(e). The reasoning of the Addl. CIT is, advance created in the name of assessee was only through book entry and no payment was made and secondly, there

INDUKURI SYAM PRASAD REDDY, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeals of both assessee’s are allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blesmt Indukuri Sundari V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aakpi8049P (Appellant) (Respondent) Shri Indukuri Syam Prasad Reddy V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aadpi1621C (Appellant) (Respondent) : Shri Mohammad Afzal Assessee By Department By : Shri M.V.S.T. Sai

deemed dividend u/s 2(22)(e). However, while according his approval in terms with section 153D, Addl. CIT, who is range head directed Assessing Officer not to make addition u/s 2(22)(e). The reasoning of the Addl. CIT is, advance created in the name of assessee was only through book entry and no payment was made and secondly, there

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD vs. MANDAVA HOLDINGS PRIVATE LIMITED, HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 Dy. C.I.T. Vs. M/S. Mandava Holdings Circle 16(2) (P) Ltd, Hyderabad Hyderabad Pan:Aafcm4964M (Appellant) (Respondent) Assessee By: Shri A.V.Raghuram, Advocate Revenue By: Shri Rajendra Kumar, Cit(Dr) Date Of Hearing: 13/07/2022 Date Of Pronouncement: 19/07/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Revenue Is Directed Against The Order Dated 19.9.2017 Of The Learned Cit (A)-4, Hyderabad Relating To A.Y.2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Company Is Engaged In The Business Of Core Investment & Filed Its Return Of Income Admitting Total Loss At (-) Rs 1,91,29,508/-. Subsequently, The Assessee Filed Revised Return Of Income On 30.11.2014 Declaring Total Loss Of Rs.1,43,53,566/-. The Return Was Processed U/S 143(1) Of The I.T. Act. Subsequently, The Case Was Selected For Scrutiny & The Statutory Notices Were Issued To The Assessee. During The Course Of Assessment Proceedings, The Page 1 Of 7

dividend income during this assessment year”. 4. Aggrieved with such order of the learned CIT (A), the Revenue is in appeal before the Tribunal by raising the following grounds of appeal: 1. The CIT (A) erred in deleting the disallowance u/s 14A of Rs.1,66,03,554/- 2. The CIT(A) erred in ignoring CBDT's Circular No.5

OSS PRASAD, HYD,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1, HYD, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2004-05 Shri O.S.S. Prasad, Vs. Acit, Central Circle-1, Hyderabad. Hyderabad.

deemed dividend. He further submitted that this is trading transaction and not a loan or advance and hence the disallowance

AGILA SPECIALTIES PRIVATE LIMITED(NOW MERGED WITH MYLAN LABORATORIES LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2012-13 Agila Specialities Private Vs. Acit, Limited, Circle-16(2), (Now Merged With Mylan 2Nd Floor, B-Block, Laboratories Limited) Income Tax Towers, Plot No. 564/A/22, Road Masabtank, No. 92, Jubilee Hills, Hyderabad – 004. Hyderabad, Telangana-34. Pan: Aaacq 1091 Q (Appellant) (Respondent) Assessee By: Sri Sharath Rao Revenue By: Smt. Nivedita Biswas-Dr Date Of Hearing: 03/09/2019 Date Of Pronouncement: 30/10/2019 Order Per A. Mohan Alankamony, Am.:

disallowing the deemed expenditure attributable to exempt income viz., dividend income U/s. 10 of the Act and Section 115JB of the Act is also

DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(1), HYDERABAD vs. DRS LOGISTICS PRIVATE LIMITED , SECUNDERABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

disallowed aggregating short computation of tax to the tune of Rs.23,43,411/- (Rs.22,12,063/- u/s 234A + Rs.1,31,348/- U/s. 43B). C) Observations : v) It is observed that from the tax audit report, the assessee has granted loan to 21 parties and the max. amount involved during the year and the balance such loans aggregates to Rs.73

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-3(1), HYDERABAD vs. MYTRAH ENERGY (INDIA) PRIVATE LIMITED, HYDERABAD

Bench: Shri D.Karunakara Rao & Shri V.Durga Raoappellant Respondent

deemed dividend u/s.2(22)(e) of the Act are not attracted to the transactions of receipt/payment of moneys between eh Appellant and its subsidiaries.” The above Ground is common in both the appeals. 3. Before us, at the outset, Ld.Counsel for the assessee submitted that the facts relating to the said addition includes that the payments were made

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. MYTRAH ENERGY (INDIA) PRIVATE LIMITED, HYDERABAD

Bench: Shri D.Karunakara Rao & Shri V.Durga Raoappellant Respondent

deemed dividend u/s.2(22)(e) of the Act are not attracted to the transactions of receipt/payment of moneys between eh Appellant and its subsidiaries.” The above Ground is common in both the appeals. 3. Before us, at the outset, Ld.Counsel for the assessee submitted that the facts relating to the said addition includes that the payments were made

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-3(1), HYDERABAD vs. MYTRAH ENERGY (INDIA) PRIVATE LIMITED, HYDERABAD

Bench: Shri D.Karunakara Rao & Shri V.Durga Raoappellant Respondent

deemed dividend u/s.2(22)(e) of the Act are not attracted to the transactions of receipt/payment of moneys between eh Appellant and its subsidiaries.” The above Ground is common in both the appeals. 3. Before us, at the outset, Ld.Counsel for the assessee submitted that the facts relating to the said addition includes that the payments were made

MYTRAH ENERGY(INDIA) PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

Bench: Shri D.Karunakara Rao & Shri V.Durga Raoappellant Respondent

deemed dividend u/s.2(22)(e) of the Act are not attracted to the transactions of receipt/payment of moneys between eh Appellant and its subsidiaries.” The above Ground is common in both the appeals. 3. Before us, at the outset, Ld.Counsel for the assessee submitted that the facts relating to the said addition includes that the payments were made

MYTRAH ENERGY (INDIA) PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

Bench: Shri D.Karunakara Rao & Shri V.Durga Raoappellant Respondent

deemed dividend u/s.2(22)(e) of the Act are not attracted to the transactions of receipt/payment of moneys between eh Appellant and its subsidiaries.” The above Ground is common in both the appeals. 3. Before us, at the outset, Ld.Counsel for the assessee submitted that the facts relating to the said addition includes that the payments were made

CAPITAL FORTUNES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE - 6(1), IT TOWERS

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.724/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. Capital Fortunes Pvt. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan:Aabcc5489P (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri C S Subrahmanyam, C.A. & Shri V Siva Kumar,Advocate रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 16/09/2025 घोर्णध की तधरीख/Pronouncement: 19/09/2025

dividend income, and disallowance of employees’ contribution. These go to the merits of computation of income and require verification of facts. In our considered view, these claims of the assessee deserve to be adjudicated on merits. The denial of relief solely on the ground of technical merger is not justified. Therefore, in the interest of substantial justice, we deem

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE-1(4), HYDERABAD vs. MEDHA SERVO DRIVES PRIVATE LIMITED, HYDERABAD

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

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

dividend income during the year, disallowance made by the Assessing Officer is deleted. 16. Department is in appeal against such deletion of disallowance. Ground Nos (vi), (vii) and (viii) of the grounds of appeal taken by the Department indicate that the Department is claiming that disallowance is in order even if there is no exempt income. This proposition

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE-1(4), HYDERABAD vs. MEDHA SERVO DRIVES PRIVATE LIMITED, HYDERABAD

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

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

dividend income during the year, disallowance made by the Assessing Officer is deleted. 16. Department is in appeal against such deletion of disallowance. Ground Nos (vi), (vii) and (viii) of the grounds of appeal taken by the Department indicate that the Department is claiming that disallowance is in order even if there is no exempt income. This proposition

ASIAN INSTITUTE OF GASTROENTEROLOGY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2020-2021 and 2021-2022 are allowed

Bench: Shri Manjunatha G & Shri Ravish Sood

deemed to be erroneous in so far as it is prejudicial to the interests of revenue. Therefore, observed that, since the Assessing Officer has not verified the issue in light of relevant provisions of the Act and also simply accepted the explanation of assessee with regard to disallowance contemplated under section 14A read with Rule 8D of I.T. Rules

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

Deemed. Dividend. 5. The Ld.CIT(A) erred in appreciating the fact that the outstanding debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact loan/advance which attracts the provisions of section 2(22)(e) of the Act. 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of bulk drugs