PRYSMIAN CAVI E SISTEMI S.R.L,HYDERABAD vs. DCIT (INT,TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

193/- against brought\nforward losses of Rs.4,74,89,404/-. The return of income of the assessee was\nselected for scrutiny and the Learned Assessing Officer (“Ld. AO”) passed an\norder under section 143(3) of the Income Tax Act, 961 (“the Act\") on\n29.03.2004, making total disallowances

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)

193/-. 5. Thereafter, the AO observed based on the facts, viz., (i) that the assessee company had reimbursed some expenses of Rs.6,54,33,770/- to M/s. Countrywide Finance Corporation and M/s. CW(UK) Services without any deduction of tax at source (TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

disallowed its profits but only determined the ALP of the gain obtained on account of excess charging of overhead costs by the chilling units at the stage of transfer of the chilled milk to the processing units. 27. Accordingly, the TPO, vide his order passed u/s 92CA(3) of the Act, determined the arms length price (ALP) of the gain

SPECTRUM POWER GENERATION LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(2), HYDERABAD

In the result, appeal of the assessee is allowed

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

disallowance under section 40(a)(ia) of the Act, and interest presupposes the existence of a debt and the relationship of debtor and creditor and in the case of the assessee there is no such debt. Nor did the assessee make any payment as interest to the creditors. Ld. AR submitted that the decision in Palam Gas Services

PRYSMIAN CAVI E SISTEMI SRL INDIA PROJECT OFFICE (FORMERLY PIRELLI CAVI SISTEMI S P A INDIA PROJECT OFFICE),HYDERABAD vs. DCIT,( INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

193/- against brought\nforward losses of Rs.4,74,89,404/-. The return of income of the assessee was\nselected for scrutiny and the Learned Assessing Officer (“Ld. AO”) passed an\norder under section 143(3) of the Income Tax Act, 961 (“the Act\") on\n29.03.2004, making total disallowances

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. BHARAT FINANCIAL INCLUSION LIMITED(FORMERLY SKS MICROFINANCE LIMITED), HYDERABAD

In the result, appeal of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahuassessment Year: 2014-15 Bharat Financial Inclusion Vs. Dy. Commissioner Of Ltd., Hyderabad. Income-Tax, Circle – 1(2), Hyderabad. Pan-Aaics2940J (Appellant) (Respondent) Assessment Year: 2012-13 Dy. Commissioner Of Vs. Bharat Financial Inclusion Income-Tax, Ltd., Hyderabad. Circle – 1(2), Hyderabad Pan-Aaics2940J (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri Sunil Kumar Pandey Date Of Hearing: 22/02/2021 Date Of Pronouncement: 20/04/2021

193/- was claimed as “provision for gratuity” which remained unpaid as on the date of filing of return and the same was not disallowed in the computation of income. Referring to the provisions of section

BHARAT FINANCIAL INCLUSION LIMITED ,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result, appeal of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahuassessment Year: 2014-15 Bharat Financial Inclusion Vs. Dy. Commissioner Of Ltd., Hyderabad. Income-Tax, Circle – 1(2), Hyderabad. Pan-Aaics2940J (Appellant) (Respondent) Assessment Year: 2012-13 Dy. Commissioner Of Vs. Bharat Financial Inclusion Income-Tax, Ltd., Hyderabad. Circle – 1(2), Hyderabad Pan-Aaics2940J (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri Sunil Kumar Pandey Date Of Hearing: 22/02/2021 Date Of Pronouncement: 20/04/2021

193/- was claimed as “provision for gratuity” which remained unpaid as on the date of filing of return and the same was not disallowed in the computation of income. Referring to the provisions of section

AMARA RAJA ENERGY AND MOBILITY LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

In the result, appeal of the Assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.791/Hyd/2025 Assessment Year 2021-2022 Amara Raja Energy & Mobility Limited, The Dcit, Circle-1(1), Vs. Tirupati – 517 520. Tirupati Pan Aabca9264E (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca E Phalguna Kumar राज" व "ारा /Revenue By: Sri Pavan Kumar Beerla, Cit-Dr

section 263 of the Act, viz., (1) that the assessment order is erroneous; and (ii) that the assessment order is prejudicial to the interest of Revenue, which are to be cumulatively satisfied. 3. The Ld. Principal CIT, Tirupati failed to conclude that the Assessment Order is both erroneous and prejudicial to the interests of the revenue. The Ld. Principal

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)., HYDERABAD vs. SUPER DAIRY FARM., HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.1287 & 1288/Hyd/2017 (निर्धारण वर्ष / Assessment Years: 2012-13 & 2013-14) Super Dairy Farm, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Circle – 4(1), Hyderabad. Pan : Aajfs7269L. अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No.1265/Hyd/2017 (निर्धारण वर्ष / Assessment Year: 2013-14) The Assistant Vs. Super Dairy Farm, Commissioner Of Income Hyderabad. Tax, Circle – 4(1), Hyderabad. Pan : Aajfs7269L. अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

193/- towards interest paid to Hyderabad Mutual Benefit Society (HMBS): Page 5 of 30 6. Issue No.1 covers grounds 1 to 3 in assessee’s appeals for A.Y. 2012-13 and 2013-14. The relevant portion from assessment order and the order of ld.CIT(A), respectively, read as under : “Disallowance of interest : (Assessment Order) IN response to the notices issued

SUPER DAIRY FARM.,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)., HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.1287 & 1288/Hyd/2017 (निर्धारण वर्ष / Assessment Years: 2012-13 & 2013-14) Super Dairy Farm, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Circle – 4(1), Hyderabad. Pan : Aajfs7269L. अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No.1265/Hyd/2017 (निर्धारण वर्ष / Assessment Year: 2013-14) The Assistant Vs. Super Dairy Farm, Commissioner Of Income Hyderabad. Tax, Circle – 4(1), Hyderabad. Pan : Aajfs7269L. अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

193/- towards interest paid to Hyderabad Mutual Benefit Society (HMBS): Page 5 of 30 6. Issue No.1 covers grounds 1 to 3 in assessee’s appeals for A.Y. 2012-13 and 2013-14. The relevant portion from assessment order and the order of ld.CIT(A), respectively, read as under : “Disallowance of interest : (Assessment Order) IN response to the notices issued

SUPER DAIRY FARM.,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)., HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.1287 & 1288/Hyd/2017 (निर्धारण वर्ष / Assessment Years: 2012-13 & 2013-14) Super Dairy Farm, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Circle – 4(1), Hyderabad. Pan : Aajfs7269L. अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No.1265/Hyd/2017 (निर्धारण वर्ष / Assessment Year: 2013-14) The Assistant Vs. Super Dairy Farm, Commissioner Of Income Hyderabad. Tax, Circle – 4(1), Hyderabad. Pan : Aajfs7269L. अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

193/- towards interest paid to Hyderabad Mutual Benefit Society (HMBS): Page 5 of 30 6. Issue No.1 covers grounds 1 to 3 in assessee’s appeals for A.Y. 2012-13 and 2013-14. The relevant portion from assessment order and the order of ld.CIT(A), respectively, read as under : “Disallowance of interest : (Assessment Order) IN response to the notices issued

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

disallowance of Rs. 2,67,641/- by the AO on account of belated payment of PF and ESI is concerned, the ld.CIT(A) directed the AO to delete the addition if the amounts are paid before the due date filing of return of income. 9. Aggrieved with such order of the Ld.CIT(A), the revenue is in appeal before

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

disallowance of Rs. 2,67,641/- by the AO on account of belated payment of PF and ESI is concerned, the ld.CIT(A) directed the AO to delete the addition if the amounts are paid before the due date filing of return of income. 9. Aggrieved with such order of the Ld.CIT(A), the revenue is in appeal before

DCIT., CIRCLE 8(1), HYDERABAD vs. EAST INDIA PETROLEUM LIMITED, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.1087/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19) Deputy Commissioner Of Vs. East India Petroleum Income Tax Limited Circle-8(1)(Incharge) Hyderabad Hyderabad [Pan : Aaace4494K] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri H.Srinivasulu, Ar रधजस् व द्वधरध/Revenue By: Ms.M.Narmada, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 16/01/2025 घोर्णध की तधरीख/Date Of 06/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Revenue Is Directed Against Order Dated 19.08.2024 Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre (Nfac), Delhi, Pertaining To A.Y.2018-19. 2. The Brief Facts Of The Case Are That The Assessee, Engaged In The Business Of Providing Terminalling Services To Oil Marketing Companies For Storage Of Bulk Liquid Products Including Fuels Like High Speed Diesel, Motor Spirit, Petroleum

disallowed the depreciation claimed on goodwill, only on the ground that the asset has not been put to use, as required u/s 32 of the Act. However, the fact remains that, the concept of user has to be interpreted in the context of intangible assets, which means, the existence of goodwill arising from the amalgamation tantamounts to user and therefore

INCOME TAX OFFICER, WARD-2(1), HYDERABAD vs. NARASIMHA REDDY DUTHALA, HYDERABAD

In the result, appeal of the Revenue is dismissed

193/- after\ndeducting indexed cost of acquisition of Rs.2,21,72,590/-.\nFurther, out of the total long term capital gains, the\nassessee has claimed exemption under section 54F of the\nAct to the tune of Rs.53,22,48,667/- being investment made\nfor purchase of land for Rs.43,83,37,000/- and further\ndeposited Rs.10,67,00,000/- under

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

disallowed the claim of deduction, inter-alia, on the ground that a claim not made in the original return filed under Section 139(1) and sought to be made for the first time in a return filed pursuant to a notice under Section 153A of the Act would not be maintainable. Further, the assessee was also found to be ineligible

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(1), HYDERABAD vs. ACP INDUSTRIES LIMITED, HYDERABAD

Appeals are treated as allowed for statistical purposes in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahuappellant Respondent

Section 14A disallowance of Rs.23,98,438/-, notional interest disallowance/addition of Rs.1,92,67,755/-, un-accounted income of Rs.6,16,37,930/- and un-secured :- 2 -: ITA Nos. 193

ACP INDUSTRIES LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

Appeals are treated as allowed for statistical purposes in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahuappellant Respondent

Section 14A disallowance of Rs.23,98,438/-, notional interest disallowance/addition of Rs.1,92,67,755/-, un-accounted income of Rs.6,16,37,930/- and un-secured :- 2 -: ITA Nos. 193