MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

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

22)(e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of drugs and pharmaceuticals. A search and seizure operation under Section 132 of the Income Tax Act was carried out in M/s. MSN Group of cases on 24.02.2021. The appellant M/s. MSN Pharmachem Private Limited (hereinafter

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

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

22)(e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of drugs and pharmaceuticals. A search and seizure operation under Section 132 of the Income Tax Act was carried out in M/s. MSN Group of cases on 24.02.2021. The appellant M/s. MSN Pharmachem Private Limited (hereinafter

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

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. 6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22

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

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. 6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22

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

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. 6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22

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

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. 6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22

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

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. 6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22

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

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

22 ITA No. 385 & 386/Hyd/2015 making the statutory disallowance under section 14A of the Act, learned CIT(A) proposed to make

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

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

22 ITA No. 385 & 386/Hyd/2015 making the statutory disallowance under section 14A of the Act, learned CIT(A) proposed to make

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

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

22 ITA No. 385 & 386/Hyd/2015 making the statutory disallowance under section 14A of the Act, learned CIT(A) proposed to make

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)

Section 40(a)(ia) of the Act. 20. To sum up, out of the disallowance of Rs. 13,02,340/-, the assessee gets relief of Rs. 45,086/-, and the balance addition of Rs. 12,57,454/- is upheld. 21. In the result, the appeal of assessee in ITA No.280/Hyd/2025 is partly allowed. ITA No.281/Hyd/2025 for A.Y. 2018-19 22

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)

Section 40(a)(ia) of the Act. 20. To sum up, out of the disallowance of Rs. 13,02,340/-, the assessee gets relief of Rs. 45,086/-, and the balance addition of Rs. 12,57,454/- is upheld. 21. In the result, the appeal of assessee in ITA No.280/Hyd/2025 is partly allowed. ITA No.281/Hyd/2025 for A.Y. 2018-19 22

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)

Section 40(a)(ia) of the Act. 20. To sum up, out of the disallowance of Rs. 13,02,340/-, the assessee gets relief of Rs. 45,086/-, and the balance addition of Rs. 12,57,454/- is upheld. 21. In the result, the appeal of assessee in ITA No.280/Hyd/2025 is partly allowed. ITA No.281/Hyd/2025 for A.Y. 2018-19 22

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, instead of directing the Ld. AO to redo the entire assessment de novo. 10.2 Further, we have gone through para no.22 of the order of this Tribunal in the assessee’s own case for A.Y. 2017–18 in ITA No. 676/Hyd/2020 dated 04.09.2024, which is to the following effect : “ 22

INCOME TAX OFFICER, WARD-1(3), HYDERABAD vs. BHAGYANAGAR INDIA LIMITED , SECUNDERABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1200/Hyd/2019 (निर्धारण वर्ा/Assessment Year:2016-17) Income Tax Officer, M/S. Bhagyanagar India Ward-1(3), Hyderabad. Vs. Limited, Hyderabad. Pan:Aaacb8963C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.C. Devdas, C.A. रधजस् व द्वधरध/Revenue By: Shri Narender Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 24/07/2025 घोर्णध की तधरीख/Pronouncement: 08/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Hyderabad (“Ld. Cit(A)”), Dated 16.05.2019 For The A.Y. 2016-17. 2. The Revenue Has Raised The Following Grounds Of Appeal:

disallowance of Rs.2,22,94,090/- made on account of amortisation of FCMITDA contending that such amortisation not a reserve to be added under 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

disallowed interest of Rs. 11,08,678/- under Section 36(1)(iii) of the Act. 22. Aggrieved by the order

CASPIAN IMPACT INVESTMENTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.749/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Caspian Impact Vs. Dy.Cit Investments Private Ltd, Circle 1(1) Hyderabad Hyderabad Pan:Aadcs4132K (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Hiten Thakkar, Advocate राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 25/09/2025 घोषणा की तारीख/Pronouncement: 03/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Caspian Impact Investments Private Limited, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Addl/Jcit (A)-1, Mumbai (“Ld. First Appellate Authority”), Dated 27.02.2025 For The A.Y. 2019-20. 2. The Assessee Has Raised The Following Grounds Of Appeal:

section 143(1)(a) is bad in law. 7. On the disallowance of Rs.13,22,458/- under section 37(1), the Ld. AR drew

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. Ground No.5 raised by the assessee is in respect of initiation of penalty proceedings by the Ld. AO under section 270A of the Act. The initiation of penalty proceedings is only a consequential and preliminary