PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(4), HYDERABAD

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

Bench: Shri Manjunatha G. Hon’Ble & Shri K. Narasimha Chary, Hon’Bleassessment Year – 2017-18 Prathima Infrastructure Limited, Vs. The Assistant Commissioner Of Income Tax, Filmnagar, Central Circle – 2(4), Hyderabad. Hyderabad. Pan : Aabcp2098P. (Respondent) (Appellant) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri B. Bala Krishna, Cit-Dr Date Of Hearing: 10.10.2024 Date Of Pronouncement: 27.11.2024

5. Being aggrieved by the assessment order, the assessee preferred an appeal before the LD.CIT(A). Before the LD.CIT(A), the assessee reiterated its arguments made before the AO and 7 submitted that, it has satisfied all the three conditions provided under Section 80IA(4) of the Act, for claiming deduction towards profits derived from eligible project. The appellant further

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Disallowance of CSR expenses of Rs. 1,42,97,133/- against the returned income of Rs. 50,81,16,931/-. 2.1 Feeling aggrieved, the assessee raised certain objections before the Ld. DRP. The Ld. DRP, after considering the submissions of the assessee and also going through the material available on record, dismissed the objections raised by the assessee. Thereafter

MAHESWARI MINING & ENERGY PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri K. Narasimha Charyassessment Years: 2016-17 Maheswari Mining & Vs. Asst. Commissioner Of Energy Pvt. Ltd., Income-Tax, Hyderabad. Circle – 16(2), Hyderabad. Pan – Aagcm0805N (Appellant) (Respondent) Assessee By: S/Shri Y. Ratnamkar& B. Satyanarayana Murthy Revenue By: Shri Y.V.S.T. Sai Date Of Hearing: 21/04/2022 Date Of Pronouncement: /04/2022

disallowed the claim on the short ground that the benefit is not available to the appellant as the notification specifying Ranga Reddy District as backward area was published on 20.07.2016 and therefore the Appellant Company is not eligible to the deduction as the addition and installation of the machinery were made prior to the said date. Aggrieved with the action

MRL TRADING COMPANY,HYDERABAD vs. ITO., WARD-7(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.29/Hyd/2025

disallowance by giving the reasoning in Paras 3.5 and 3.6 as under: “3.5. That being the case question arises as to whether any person who received such SBN note after 09.11.2016 can bring it into books of account. "Here the basic principle of accountancy has to be relied upon. The money measurement concept underlines the fact that in accountancy

VIVIMED LABS LIMITED,HYDERABAD vs. 500082 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

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

5. We have given our thoughtful consideration to rival pleadings qua the impugned corporate guarantee issue. The first and foremost question as to whether a corporate guarantee amounts to an international transactions or not stands decided in Revenue’s favour and against the assessee in PCIT Vs. Redington (India) Limited (2020) 122 taxmann.com 126 (Madras). Their lordships have considered Explanation

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

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

5. We have given our thoughtful consideration to rival pleadings qua the impugned corporate guarantee issue. The first and foremost question as to whether a corporate guarantee amounts to an international transactions or not stands decided in Revenue’s favour and against the assessee in PCIT Vs. Redington (India) Limited (2020) 122 taxmann.com 126 (Madras). Their lordships have considered Explanation

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

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

5. We have given our thoughtful consideration to rival pleadings qua the impugned corporate guarantee issue. The first and foremost question as to whether a corporate guarantee amounts to an international transactions or not stands decided in Revenue’s favour and against the assessee in PCIT Vs. Redington (India) Limited (2020) 122 taxmann.com 126 (Madras). Their lordships have considered Explanation

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX , HYDERABAD

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

5. We have given our thoughtful consideration to rival pleadings qua the impugned corporate guarantee issue. The first and foremost question as to whether a corporate guarantee amounts to an international transactions or not stands decided in Revenue’s favour and against the assessee in PCIT Vs. Redington (India) Limited (2020) 122 taxmann.com 126 (Madras). Their lordships have considered Explanation

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MEGHA ENGINEERING AND INFRASTRUCTURES LIMITED, HYDERABAD

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

Bench: Shri Manjunatha G. Hon’Ble & Shri Prakash Chand Yadav, Hon’Bleassessment Year – 2020-21 The Assistant Commissioner Of Vs. M/S.Megha Engineering & Infrastructure Ltd. Income Tax, Hyderabad. Central Circle – 2(1), Hyderabad. Pan : Aaecm7627A

5. The ld.CIT(A), after considering relevant submissions of the assessee, as well as the order of the Assessing Officer observed that, as could be seen from the facts brought on record, the appellant company is engaged into infrastructure development activity of various kinds, which are shown to be awarded directly as main developer / builder, while some were awarded

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED., HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

disallowance of interest, if any, and the reasons thereof so that the assessee gets an opportunity to file written objection and that ~ the assessment completed after giving sufficient opportunity to the assessee." 6.1 In the course of passing consequential order by the lower authorities, the assessee has not led any evidence to show the commercial expediency to advance funds

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

disallowance of interest, if any, and the reasons thereof so that the assessee gets an opportunity to file written objection and that ~ the assessment completed after giving sufficient opportunity to the assessee." 6.1 In the course of passing consequential order by the lower authorities, the assessee has not led any evidence to show the commercial expediency to advance funds

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

disallowance of interest, if any, and the reasons thereof so that the assessee gets an opportunity to file written objection and that ~ the assessment completed after giving sufficient opportunity to the assessee." 6.1 In the course of passing consequential order by the lower authorities, the assessee has not led any evidence to show the commercial expediency to advance funds

DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

disallowance of interest, if any, and the reasons thereof so that the assessee gets an opportunity to file written objection and that ~ the assessment completed after giving sufficient opportunity to the assessee." 6.1 In the course of passing consequential order by the lower authorities, the assessee has not led any evidence to show the commercial expediency to advance funds

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

184 ITR (St.) 137 explained the scope and ambit of section 80HHC and the mode of determination of profits derived by an assessee from the export of goods. I.T.A.T., Special Bench in the case of lnternational Research Park Laboratories Ltd. (supra), after following the aforesaid Circular, held that straight jacket formula given rn sub-section (3) has to be followed

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

Appeals are dismissed therefore

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

5. The assessee has drawn a strong support from the CIT(A)’s detailed findings extracted in the preceding paragraphs. Mr.Afzal invited our attention to assessee’s detailed representation submitted before hon'ble President of the tribunal u/s.255(3) of the Act, seeking to constitute a Special Bench in light of various conflicting decisions on various facts of Section

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

Appeals are dismissed therefore

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

5. The assessee has drawn a strong support from the CIT(A)’s detailed findings extracted in the preceding paragraphs. Mr.Afzal invited our attention to assessee’s detailed representation submitted before hon'ble President of the tribunal u/s.255(3) of the Act, seeking to constitute a Special Bench in light of various conflicting decisions on various facts of Section

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

Appeals are dismissed therefore

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

5. The assessee has drawn a strong support from the CIT(A)’s detailed findings extracted in the preceding paragraphs. Mr.Afzal invited our attention to assessee’s detailed representation submitted before hon'ble President of the tribunal u/s.255(3) of the Act, seeking to constitute a Special Bench in light of various conflicting decisions on various facts of Section

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

Appeals are dismissed therefore

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

5. The assessee has drawn a strong support from the CIT(A)’s detailed findings extracted in the preceding paragraphs. Mr.Afzal invited our attention to assessee’s detailed representation submitted before hon'ble President of the tribunal u/s.255(3) of the Act, seeking to constitute a Special Bench in light of various conflicting decisions on various facts of Section