DR. REDDYS LABORATORIES LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

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

Bench: Shri Laxmi Prasad Sahu & Shri K.Narasimha Charyassessment Years: 2007-08 Dr.Reddy’S Laboratories Vs. Dcit,Circle-17(1) Limited Hyderabad 8-2-337, Road No.3 Banjara Hills Hyderabad-500 034

disallowed the excess claim of deduction in respect of Yanam unit and Baddi Unit. The assessee is running four units, which are eligible for deduction/exemptions as per u/s. 10B, 80IB and 80IC. The ld. AR of the assessee has vehemently submitted that there was a debatable issue to which the rectification cannot be made u/s 154

VE VEE'S MANAGERIAL SERVICES,HYDERABAD vs. DCIT, CIRCLE-9(1), HYDERABAD

In the result, ITA No. 167/Hyd/2022 & 168/Hyd/2022 are allowed and ITA No

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

disallowance of Rs. 1,57,34,616/- u/s. 36(i)(va) of I.T.Act on account of delayed payment of employees’ contribution to PF and ESIC. The assessee filed a rectification application u/s 154

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

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

rectification Madhucon Projects Limited, Hyderabad. action u/s 154. The Assessing Officer has therefore, rightly rejected the petition u/s 154 seeking deduction u/s 80IA.” 27. The assessee vide his application dt.04.07.2013 filed two M.A. Nos.171 and 172 /Hyd/2013 in ITA Nos.805 and 806/Hyd/2010 for A.Y.s 2005-06 and 2006-07 before the Tribunal. The submissions made by the assessee

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

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

rectification Madhucon Projects Limited, Hyderabad. action u/s 154. The Assessing Officer has therefore, rightly rejected the petition u/s 154 seeking deduction u/s 80IA.” 27. The assessee vide his application dt.04.07.2013 filed two M.A. Nos.171 and 172 /Hyd/2013 in ITA Nos.805 and 806/Hyd/2010 for A.Y.s 2005-06 and 2006-07 before the Tribunal. The submissions made by the assessee

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

rectification Madhucon Projects Limited, Hyderabad. action u/s 154. The Assessing Officer has therefore, rightly rejected the petition u/s 154 seeking deduction u/s 80IA.” 27. The assessee vide his application dt.04.07.2013 filed two M.A. Nos.171 and 172 /Hyd/2013 in ITA Nos.805 and 806/Hyd/2010 for A.Y.s 2005-06 and 2006-07 before the Tribunal. The submissions made by the assessee

ROCKSALT INTERACTIVE GAMES PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-3(2) , HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarm/S. Rocksalt Interactive Income Tax Officer, Vs. Games Pvt. Ltd., Ward 3(2), Hyderabad. Hyderabad. Pan Aafcr3033A (Appellant) (Respondent) Appellant By : Shri P. Murali Mohan Rao, C.A. Respondent By : Shri Vijay Bhaskar Reddy, Cit-Dr Date Of Hearing : 16.11.2022 Date Of Pronouncement : 12.12.2022 O R D E R Per Shri Laliet Kumar, J.M. : This Appeal Filed By The Assessee Is Directed Against The Order Dt.30.03.2020 Of The Learned Pr. Commissioner Of Income Tax/Cit-3, Hyderabad Relating To Assessment Year 2015-16 U/S. 263 Of The Income Tax Act, 1961 (In Short ‘The Act’).

disallowing the set off of brought forward loss of Rs. 92,85,891. In our view exercise of power u/s 154 of the Act in the present case is totally invalid. As ;can be seen, the loss of Rs. 92,85,891 was quantified and allowed to be carried forward while processing return filed by assessee u/s

CES LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2020-21 Ces Limited, Vs. The Deputy Commissioner Of Income Tax, Hyderabad. Circle – 1(1), Hyderabad. Pan : Aadcs4564P. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao, C.A. Revenue By: Ms. Sheetal Sarin, Sr. Ar. Date Of Hearing: 19.03.2024 Date Of Pronouncement: 22.03.2024

u/s 154 which clearly states that there is an error while passing the rectification order dated 03.06.2022. 3. The Ld. CIT(A) ought to have appreciated the fact that the Ld. CPC, Bangalore has erred in making the disallowance

SEW KRISHNAGAR BAHARAMPORE HIGHWAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.193/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2020-21) Sew Krishnagar Vs. Dcit, Circle-3(1) Baharampore Highways Hyderabad Limited Hyderabad [Pan :Aapcs5143Q] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Prasad & Shri K.Rajendra Kumar, Ar रधजस् व द्वधरध/Revenue By: Ms.M.Narmada, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 21/01/2025 घोर्णध की तधरीख/Date Of 21/01/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.12.2023 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre (Nfac), Hyderabad, Pertaining To A.Y.2020-21. 2. The Appeal Filed By The Assessee Is Barred By Limitation By 9 Days. It Has Moved A Condonation Petition Explaining Reasons Thereof. We Have Heard Both The Parties & Having Regard To The Reasons Given In The Petition, We Condone The Delay & Admit The Appeal For Hearing.

rectification petition u/s 154 of the Act and the CPC passed order u/s 154 dated 11.01.2022 and rejected the contentions of the assessee. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before the CIT(A). Before the Ld.CIT(A), the assessee submitted that it has debited total interest expenditure of Rs.137.82 crores

ANDHRA PRAGATHI FARMERS SERVICE CO-OP SOCIETY,RAMADURGAM vs. ITO, WARD-1, ADONI

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.661/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2018-19) Andhra Pragathi Farmers Vs. Income Tax Officer Service Coop. Society, Ward – 1 Ramadurgam Adoni Pan:Aaaar1876J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Srinath Sadanala, Dr सुनवाई की तारीख/Date Of Hearing: 02/04/2025 घोषणा की तारीख/Pronouncement: 03/04/2025 आदेश/Order

disallowed the claim of the assessee only on the ground that there was a delay in filing the return of income. Since the Assessing Officer already allowed the claim of the assessee u/s 80P(2) while passing the assessment order u/s 143(3) dated 3/3/2021, therefore, a rectification order dated 8/9/2021 u/s 154

SHARAD MATHUR,HYDERABAD vs. DCIT., CIRCLE 12(1), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.331 & 332/Hyd/2024 (िनधा"रण वष"/Assessment Years:2019-20 & 2021-22) Shri Sharad Mathur Vs. Dy. C. I. T. Hyderabad Circle 12(2) Pan:Aogpm3520B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri B.Satyanarayana Murthy,Ca राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 03/06/2024 घोषणा की तारीख/Pronouncement: /06/2024 आदेश/Order

disallowance of Rs.1,17,02,466/- being Foreign Tax Credit claimed by the assessee by way of tax relief u/s 90 of the I.T. Act, 1961. 3. Facts of the case, in brief, are that the appeal instituted on 14.11.2022 emanates from the rectification of the intimation order u/s 154

S K G REFRACTORIES LIMITED, HYDERABAD,HYDERABAD vs. ACIT, CIRCLE-3(2), HYDERABAD, HYDERABAD

Appeal is dismissed in above terms

Bench: Shri A. Mohan Alankamony & Shri S.S. Godaraassessment Year: 2006-07 Skg Refractories Limited, Vs. The Asst. Commissioner Of Hyderabad – 500063. Income Tax, Circle 3(2), Pan : Aadcs4040G. Hyderabad. (Appellant) (Respondent) Assessee By: Shri Samuel Nagadesi. Revenue By: Shri T. Sunil Goutam. Date Of Hearing: 16.02.2022 Date Of Pronouncement: 18.02.2022 O R D E R Per S. S. Godara, J.M.

rectification of the intimation already sent to the assessee. There are several judgments, wherein it was decided that such kind of mistake is not apparent from record and cannot be rectified u/s. 154. In the ease of M. Far Hotels Ltd. vs CIT Hon'ble High Court of Kerala reported in 361 ITR 442 held as under: "1. The admitted

NAGUBABU KUCHIBHOTLA,HYDERABAD vs. INCOME TAX OFFICER, WARD-12(1), HYDERABAD

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

Bench: Hon'Ble Justice (Retd.) C.V. Bhadang & Shri R.K. Panda, Vice-आ.अपी.सं /Ita No.28/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Shri Nagubabu Vs. Income Tax Officer Kuchibhotla Ward-12(1) Hyderabad Hyderabad Pan:Ahlpk3559L (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. P Prabhakara Murthy राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 15/02/2024 घोषणा की तारीख/Pronouncement: 27/02/2024 Order Per R.K. Panda, Vice-. This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.02.2023 Of The Learned Cit (A)-Nfac, Delhi, Relating To A.Y.2020-21. 2. Although A Number Of Grounds Have Been Raised By The Assessee, However, These All Relate To The Order Of The Learned Cit(A)Nfac In Upholding The Disallowance Of Rs.4,40,939/- Being Foreign Tax Credit Claimed By The Assessee By Way Of Tax Relief U/S 90 Of The I.T. Act, 1961. Page 1 Of 7

rectification application filed u/s 154 of the I.T. Act, 1961 on the ground that Form 67 was not furnished before the due date as prescribed u/s 139(1) in compliance to Rule 128(9). We find the learned CIT (A) NFAC upheld the action of the Assessing Officer on the ground that the filing of Income Tax Return offering

JAI BALAJEE SECURITY SERVICES PRIVATE LIMITED,CHITTOOR vs. ACIT, CIRCLE-1(1), TIRUPATHI

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

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

rectification order u/s. 154 of the Income Tax Act, 1961 (for short “the Act”), on 24/09/2021, disallowed the Provident Fund

CELESTIAL BIOLABS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

rectification order u/s 154 of the Act was passed after giving the opportunity of hearing to the assessee within the period of limitation. 9. We have heard the rival submissions and perused the material on record. As clear from the above noted facts, the Assessing Officer has passed the original assessment order on 31.12.2010 disallowing

CELESTIAL BIOLABS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

rectification order u/s 154 of the Act was passed after giving the opportunity of hearing to the assessee within the period of limitation. 9. We have heard the rival submissions and perused the material on record. As clear from the above noted facts, the Assessing Officer has passed the original assessment order on 31.12.2010 disallowing

CELESTIAL BIOLABS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

rectification order u/s 154 of the Act was passed after giving the opportunity of hearing to the assessee within the period of limitation. 9. We have heard the rival submissions and perused the material on record. As clear from the above noted facts, the Assessing Officer has passed the original assessment order on 31.12.2010 disallowing

LAKSHMI SHANKAR GUMUDAVELLI ,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(4), HYDERABAD

In the result, ITA No. 144/Hyd/2020 filed by the assessee is allowed, whereas ITA No

Bench: Shri Rama Kanta Panda

disallowing interest expenditure of Rs.15,85,752, which issue is highly debatable, in a proceeding under section 154 of the Act. 3. The finding of the CIT(A) that the issue is not debatable is legally incorrect in as much as investment in capital account not only earns prof1t (which is exempt from tax) but also interest income

LAKSHMI SHANKAR GUMUDAVELLI ,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(4) , HYDERABAD

In the result, ITA No. 144/Hyd/2020 filed by the assessee is allowed, whereas ITA No

Bench: Shri Rama Kanta Panda

disallowing interest expenditure of Rs.15,85,752, which issue is highly debatable, in a proceeding under section 154 of the Act. 3. The finding of the CIT(A) that the issue is not debatable is legally incorrect in as much as investment in capital account not only earns prof1t (which is exempt from tax) but also interest income

JVP SOFT PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(1), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri A. Mohan Alankamonya.Y. 2008-09 Jvp Soft Private Limited, Vs. Income Tax Officer, Hyderabad. Ward-2(1), Pan: Aaacj 5094 J Hyderabad. (Appellant) (Respondent) Assessee By Shri T. Rajendra Prasad Revenue By Shri Sunil Gowtam, Dr Date Of Hearing: 10/11/2021 Date Of Pronouncement: 06/01/2022 Order

disallowing deduction U/s. 80IA and I upheld the action of the AO. As there is delay of 76 days in filing the appeal and there is no request for condonation of delay from the appellant, the appeal is dismissed on technical grounds and on merits also.” 5. Before us, the Ld. AR reiterated the submissions made before