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 advertisement expenses of Rs. 45,000/- cannot be sustained. Therefore, we direct the A.O. to delete the addition of Rs. 45,000/- made under Section 40(a)(ia) of the Act. 19

KAUSALYA AGRO FARMS AMD DEVELOPERS PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes, in terms of our above findings

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

disallowance under section 36(1)(iii) of the Act. Therefore, respectfully following the decision of this Tribunal, as far as the other investments which are not covered in terms of commercial expediency, we restore the issue to the file of the Ld. AO for limited verification of the ITA No.804/Hyd/2025 19

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

19,036/- by making additions towards disallowance of finance charges and disallowance under Section 14A of the Act. 4. On appeal

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

19,036/- by making additions towards disallowance of finance charges and disallowance under Section 14A of the Act. 4. On appeal

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

19,036/- by making additions towards disallowance of finance charges and disallowance under Section 14A of the Act. 4. On appeal

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

19,036/- by making additions towards disallowance of finance charges and disallowance under Section 14A of the Act. 4. On appeal

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

19,036/- by making additions towards disallowance of finance charges and disallowance under Section 14A of the Act. 4. On appeal

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

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

disallowance which the learned Assessing Officer failed to do. We are in agreement with this finding of the learned CIT(A). 19. Having said that, we are of the opinion that while looking into the aspect of allowability or otherwise of an expenditure on the touch stone of section

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

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

disallowance which the learned Assessing Officer failed to do. We are in agreement with this finding of the learned CIT(A). 19. Having said that, we are of the opinion that while looking into the aspect of allowability or otherwise of an expenditure on the touch stone of section

CHINTALAPATI HOLDINGS PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD

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

disallowance which the learned Assessing Officer failed to do. We are in agreement with this finding of the learned CIT(A). 19. Having said that, we are of the opinion that while looking into the aspect of allowability or otherwise of an expenditure on the touch stone of section

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

In the result, the appeal of the assessee is partly allowed

Section 201(1A) does not assume the character of business expenditure and also cannot be regarded as compensatory payment. The learned CIT(A), after considering the relevant facts, has rightly disallowed the interest paid on TDS and the order of the learned CIT(A) should be upheld. 19

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

disallowance of Rs.13,76,205/- made under section 40(a) of the Act. Accordingly, Ground No.4 of the assessee is allowed for statistical purposes. 19

SHELADIA ASSOCIATES INC,SD ROAD vs. ADIT(INT TAXN)-2, HYDERABAD

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

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No. 537/Hyd/2023 (धििाारण वर्ा / Assessment Year: 2021-22) Sheladia Associates Inc, Adit (Int Taxn)-2, Secunderabad Vs. Hyderabad [Pan No. Aafcs7792F] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

disallowance, therefore, could be made under section 44C of the Act. 19. Insofar as the amount of Rs. 1,60,78,394/- under

ASIAN INSTITUTE OF GASTROENTEROLOGY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2020-2021 and 2021-2022 are allowed

Bench: Shri Manjunatha G & Shri Ravish Sood

disallowance under section 14A read with Rule 8D of I.T. Rules, 1962. Therefore, in our considered view, where the Assessing Officer has taken a 18 ITA.Nos.609 & 610/Hyd./2025 plausible view on the issue, after considering relevant submissions of the assessee, then, the learned PCIT cannot substitute his views on the very same issue, unless, the view taken

KASUSALYA SHELTERS PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 17. The solitary issue that came up for our consideration in Ground No.1 of the assessee's appeal is the disallowance of finance charges of Rs.18,19

KASUSALYA SHELTERS PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 17. The solitary issue that came up for our consideration in Ground No.1 of the assessee's appeal is the disallowance of finance charges of Rs.18,19

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

section 80-IA(4) of the Act observed that,- “6.2 Ground No.3 Is regarding the claim of deduction u/s.80IA(4) of Rs.43,96, 23,203/-. The AO has disallowed the 80IA deduction stating that the Joint venture has entered into agreement with the Government and not the appellant. Therefore, the AO averred that it is the Joint venture which

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

section 80-IA(4) of the Act observed that,- “6.2 Ground No.3 Is regarding the claim of deduction u/s.80IA(4) of Rs.43,96, 23,203/-. The AO has disallowed the 80IA deduction stating that the Joint venture has entered into agreement with the Government and not the appellant. Therefore, the AO averred that it is the Joint venture which