DCIT., CIRCLE-8(1), HYDERABAD vs. DBS TECHNOLOGY SERVICES INDIA PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Deputy Commissioner Of Vs. M/S. Dbs Technology Income Tax, Services India Private Circle – 8(1), Limited, Hyderabad. Hyderabad. Pan : Aafcd5584N (Appellant) (Respondent) C.O.No.2/Hyd/2023 Assessment Year 2019-20 Dbs Technology Services India Vs. Deputy Commissioner Of Private Limited, Income Tax, Circle – 8(1), Hyderabad. Hyderabad. Pan : Aafcd5584N (Cross Objector / (Appellant/Revenue) Respondent) Assessee By: Sri M. P. Lohia, C.A. Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 11.07.2023 Date Of Pronouncement: 21.07.2023 आदेश / O R D E R Per Laliet Kumar, Jm: The Appeal & Cross-Objection Filed By The Revenue For A.Y. 2019-20 Arise From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi

10A[, section 10AA], clause (b) of sub-section (1) of section 12A, section 44AB [, section 44DA, section 50B], section 80-IA, section 80-IB, section 80-IC, section 80-ID, section 80JJAA, section 80LA, section 92E, [section 115JB, 5[section 115JC] or section 115VW] [or to give a notice under clause (a) of sub-section (2) of 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

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

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)

disallowance under section 40(a) (i) of the Act against the reimbursements made to its AEs, disregarding the well settled ratio in the case of Gem Plus Jewellery India Ltd [2010] 194 Taxman 192 (Bombay). b) Erred in upholding the flawed approach adopted by the Ld. AO in not granting deduction under section 10A of the Act which was allowed

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

disallowing the claim of 80IA as the assessee was not the owner of the infrastructural facilities laid / installed / created by it. In fact, the owner of the said infrastructural facilities were the Superintendent Engineer / Chief Engineer / Project Director of the concerned Government Department. He drew our attention to pages 3 to 5 of the assessment order and had also drawn

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

disallowing the claim of 80IA as the assessee was not the owner of the infrastructural facilities laid / installed / created by it. In fact, the owner of the said infrastructural facilities were the Superintendent Engineer / Chief Engineer / Project Director of the concerned Government Department. He drew our attention to pages 3 to 5 of the assessment order and had also drawn

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

disallowing the claim of 80IA as the assessee was not the owner of the infrastructural facilities laid / installed / created by it. In fact, the owner of the said infrastructural facilities were the Superintendent Engineer / Chief Engineer / Project Director of the concerned Government Department. He drew our attention to pages 3 to 5 of the assessment order and had also drawn

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

disallowing the claim of 80IA as the assessee was not the owner of the infrastructural facilities laid / installed / created by it. In fact, the owner of the said infrastructural facilities were the Superintendent Engineer / Chief Engineer / Project Director of the concerned Government Department. He drew our attention to pages 3 to 5 of the assessment order and had also drawn

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH P. LTD.,),HYDERABAD vs. ACIT, CIRLCE-16(2), , 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

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH PRIVATE LIMITED),HYDERABAD vs. ACIT., CIRCLE-16(2), , 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

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

ACIT., CIRCLE-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

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

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

3 thereto. Therefore, he submitted that Section 153A differs from Section 147, which clearly indicates that the scheme of provision of Section 153A is different from that of Section 147. In :16: ITA Nos. 1717 to 1720/Hyd/2017 & this regard, he relied upon the following judicial precedents :  DCIT Vs. Eversmile Construction Co. (P.) Ltd. [2012] 143 TTJ 322 (Mumbai)  KNR Constructions

CORTEVA AGRISCIENCE SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

In the result, the Ground No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance of deduction under section 10 AA of the income tax act on this sum. With respect to the other sum of Rs. 4.80 crores The assessee has given foreign inward remittance certificates and such sum has also been received in India on 04/02/2011 and 24/2/2011. The provisions of section 10AA does not provide any time-limit of bringing such

SUPRIYA NAGENDLA,SECUNDERABAD vs. ITO., WARD-4(1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1521/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Smt. Supriya Nagendla Vs. Income Tax Officer Secunderabad Ward 4(1) Pan:Aaupn8127B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Assessee Smt. Supriya Nagendla राज" व "ारा/Revenue By:: Shri Abhinav Pitta, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Supriya Nagendla (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 05.08.2025 For The A.Y 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:

disallowance of severance pay solely on the ground of company deducting tax on payment and not verification of evidence, which is unjustified, especially when such an evidences and supporting produced in proceedings, and the appellant was not given an opportunity to provide the same. The additions are arbitrary, contrary to the principles of natural justice, and not sustainable

VALUE LABS LLP,HYDERABAD vs. ACIT CIRCLE-8(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Manjunatha. G & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 229/Hyd/2022 ("नधा"रण वष" / Assessment Year: 2009-10) Value Labs Llp, Vs. Acit, Hyderabad. Circle-8(1), [Pan : Aakfv2276K] Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

disallowed exemp"on on the interest income by trea"ng the same as income from other sources u/s 56 of the Act and passed assessment order dated 31/03/2013, determining the taxable income of Rs. 5,75,94,250/-, thereby allowing the exemp"on u/s 10A for a sum of Rs. 56,86,87,403/- as against the actual claim

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

10A or section 10AA or section 10B or section 10BA or under any provision of this Chapter under the heading “C-Deductions in respect of certain incomes”, no deduction shall be allowed to him thereunder Section 80AC Deduction not to be allowed unless furnished-Where in computing the total income of an assessee of the previous year relevant

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

10A or section 10AA or section 10B or section 10BA or under any provision of this Chapter under the heading “C-Deductions in respect of certain incomes”, no deduction shall be allowed to him thereunder Section 80AC Deduction not to be allowed unless furnished-Where in computing the total income of an assessee of the previous year relevant