DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

2. erred in upholding the AO's action of disallowing the expenses claimed under section 37(1) of the Act amounting to Rs. 12,77,839; 3. erred in upholding the disallowance of expenses amounting to Rs. 10,00,000 as determined by the Ld. AO on ad-hoc basis; Additional Ground 3.1. erred in disallowing the expenses pertaining

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

disallowed. This excess WDV resuted in excess claim of depreciation of Rs.3,37,71,787/-. 4 ITA Nos 573 and 5754 of 2024 VIP Private Limited ii. As per Schedule CYLA of ITR of AY 2017-18 (page 47), the assessee has a business income of Rs 7,42,25,071/-, short term capital gain

LANCO SOLAR (GUJARAT) PRIVATE LIMITED ,HYDERABAD vs. ITO., WARD-16(1), HYDERABAD

In the result, appeals filed by the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

disallowance of claim of deduction u/s 80IA of the Act by the Assessing Officer and confirmation of the same by the learned CIT (A) is highly unjustified and contrary to the law. Page 5 of 18 ITA Nos 905 and 906 of 2024 Lanco Solar Gujarat P Ltd 6. The learned DR, on the other hand, has submitted that section

LANCO SOLAR (GUJARAT) PRIVATE LIMITED ,HYDERABAD vs. ITO., WARD-16(1), HYDERABAD

In the result, appeals filed by the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

disallowance of claim of deduction u/s 80IA of the Act by the Assessing Officer and confirmation of the same by the learned CIT (A) is highly unjustified and contrary to the law. Page 5 of 18 ITA Nos 905 and 906 of 2024 Lanco Solar Gujarat P Ltd 6. The learned DR, on the other hand, has submitted that section

ROLON SEALS INTERNATIONAL,HYDERABAD vs. ITO., WARD-11(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.947/Hyd/2025 Assessment Year 2023-2024 Rolon Seals International, The Income Tax Officer, Hyderabad – 500 063. Vs. Ward-11(1), Telangana. Hyderabad. Pan Aarfr2216G (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Sashank Dundu, Advocate राज" व "ारा /Revenue By: G Saratha, Sr. Ar

disallowance referring to sub-sections (5) & (6) of section 10A/10B of the 1.T. Act, which are applicable to the deduction u/s 10AA of the I.T. Act also. The provisions of sub-sections (5) & (6) of section 10A of the LT. Act shall apply to the exemption u/s 10AA of the I.T. Act also by virtue of sub-section

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

2) of the Act and without supplying the reasons for initiation of re-assessment proceedings. 5. Erred in upholding the action of the Ld. AO in disallowing reimbursement of expenses to AEs under section 40(a)(i) of the Act. a) Erred in upholding the action of the Ld. AO in not granting deduction under section 10A

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

disallowance of the part of the amount of deduction u/s 10A, without firstly showing that there existed any arrangement between the assessee and its overseas related party, by which the transactions were so arranged as to produce more than the ordinary profits in the hands of the assessee. The assessment year under consideration is 2009-10. Neither the proviso

ACIT, CIRLCE-5 (1), , HYDERABAD vs. MARKET TOOLS RESEARCH PRIVATE LIMITED , HYDERABAD

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

10A deduction on the expenditure disallowed u/s 40(a)(ia). 12. Disallowing the income tax expenditure of Rs. 5,91,248 without appreciating the fact that the Appellant has already disallowed such amount, thereby leading to double disallowance. 13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B