NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowance of donations under Section 80G towards CSR expenditure. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Ms. Tanmayee Rajkumar, Advocate, referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.06.2024, submitted that, the assessment

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

section 153. The assessment order so passed is bad in law, void ab initio and liable to be quashed. 3. The learned AO and DRP have erred in not appreciating that the Appellant considered the payments for marketing support services and the R&D services as operating expenses while adopting TNMM at the entity level which has not been disturbed

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

section 153. The assessment order so passed is bad in law, void ab initio and liable to be quashed. 3. The learned AO and DRP have erred in not appreciating that the Appellant considered the payments for marketing support services and the R&D services as operating expenses while adopting TNMM at the entity level which has not been disturbed

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

disallowed in the previous year.\nInvestment allowance under Section 32AD\n8. On the facts and circumstances of the case and in law, the Id. AO,\nunder the direction of the Hon'ble DRP, erred in not appreciating\nthat the Appellant ought to be granted investment allowance as per\nSection 32AD of the Act.\nInitiation of penalty under Section 270A

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

disallowing the relief claimed by the Appellant of INR 31,48,038 towards foreign tax credits under section 90/91 of the Act, without considering assessee's submission and documentary evidence. 19. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in disregarding Assessee's claim for additional relief

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

disallowing for the market risk adjustment to eliminate the difference in the risk level of the Appellant and the comparable companies. 3:3 The Appellant submits that the learned AO/TPO be directed to recalculate the adjustment made by him to the Appellant's total income and to re-compute its total income and tax liability accordingly. 4:0 Transfer Pricing

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

disallowing for the market risk adjustment to eliminate the difference in the risk level of the Appellant and the comparable companies. 3:3 The Appellant submits that the learned AO/TPO be directed to recalculate the adjustment made by him to the Appellant's total income and to re-compute its total income and tax liability accordingly. 4:0 Transfer Pricing

C5 INFRA PRIVATE LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.332/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) C5 Infra (P) Ltd Vs. Acit Secunderabad Central Circle 2(3) Pan:Aafcc2138K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca Shri C. Maheshwar Reddy, Ca राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2025 घोषणा की तारीख/Pronouncement: 25/07/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated 10/03/2023 Of The Learned Cit (A)-12, Hyderabad, For The A.Y.2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

disallowance u/s 40A(3) is beyond the jurisdiction of the Assessing Officer/learned CIT (A) to make addition in the proceedings u/s 153A of the Act in the absence of any incriminating material. The excel sheet found during the search from the email ID of the Accountant of the assessee cannot be regarded as incriminating material until and unless the entries

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

disallowed the assessee’s claim for deduction under section 80C of the Act of Rs. 66,982/-. 6. Accordingly, the AO vide his order under section 147 of the Act, dated 26/03/2025, determined the income of the assessee at Rs. 8,35,157/-. 7. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

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

disallowed the assessee’s claim for deduction under section 80C of the Act of Rs. 66,982/-. 6. Accordingly, the AO vide his order under section 147 of the Act, dated 26/03/2025, determined the income of the assessee at Rs. 8,35,157/-. 7. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success

SRINIVASA REDDY YETURU,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1898/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Srinivasa Reddy Yeturu, Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aalpy0486H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, C.A राज" व "ारा/Revenue By: Shri Ashuthosh Pradhan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10/12/2025 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee, Which Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), 11, Hyderabad, Dated 01/10/2025, For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

153 of Income Tax Act. 3. On the facts and circumstance of the case, the Learned CIT(A) is not justified in dismissing the ground , issue of notice under Section 143(2) for the Asst Year 2022-23 is bad in law and also notice U/s 143(2) issued is without Jurisdiction. 4. On the facts and circumstance

SGD PHARMA INDIA PRIVATE LIMITED, ,MAHABUBNAGAR vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee in ITA\nNo

3) read with section 144C(13) of the Act,\nhaving been passed beyond the limitation period provided in terms of section 153 of the Act, is void-ab-initio,\nillegal and bad in law and is therefore liable to be quashed\nWe respectfully request that the Hon'ble Bench take this on record and proceed to decide the appeal

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

disallowance of Rs. 2,91,30,153/- made under Section 40(a)(ia) of the Act, the assessee gets relief of Rs. 2,90,67,733/- and the balance amount of Rs. 62,420/- is upheld. 42. In the result, the appeal of the assessee for A.Y.2018-19 is partly allowed. ITA No. 282 /Hyd/2025

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

disallowance of Rs. 2,91,30,153/- made under Section 40(a)(ia) of the Act, the assessee gets relief of Rs. 2,90,67,733/- and the balance amount of Rs. 62,420/- is upheld. 42. In the result, the appeal of the assessee for A.Y.2018-19 is partly allowed. ITA No. 282 /Hyd/2025

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

disallowance of Rs. 2,91,30,153/- made under Section 40(a)(ia) of the Act, the assessee gets relief of Rs. 2,90,67,733/- and the balance amount of Rs. 62,420/- is upheld. 42. In the result, the appeal of the assessee for A.Y.2018-19 is partly allowed. ITA No. 282 /Hyd/2025

RASHID HUSSAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(3), HYDERABAD

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

disallowance of his claim for deduction of expenditure of Rs.16,33,050/-. Accordingly, the CIT(A) partly allowed the appeal. 5 Rashid Hussain vs. ACIT 8. The assessee being aggrieved with the order of the CIT(A) has carried the matter in appeal before us. 9. We have heard the Ld. Authorised Representatives of both parties, perused the orders

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

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

3) and travelled up to the stage of 2nd appeal before this Tribunal and hence, the impugned disallowance is not based on any incriminating material found during the course of search & seizure action. Thus, the said addition made by the Assessing Officer by disallowing deduction u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material

ACIT CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

3) and travelled up to the stage of 2nd appeal before this Tribunal and hence, the impugned disallowance is not based on any incriminating material found during the course of search & seizure action. Thus, the said addition made by the Assessing Officer by disallowing deduction u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material