CUSTOMER LAB SOLUTIONS PRIVATE LIMITED, HYDERABAD,BANGALORE vs. ITO, WARD-1(2), HYDERABAD, HYDERABAD

In the result, the appeal of assessee is allowed

Bench: Shri D. Manmohan & Shri B. Ramakotaiah

234, tax deduction at source obligations under section 195(1) arise only if the payment is chargeable to tax in the hands of nonresident recipient. Therefore, merely because a person has not deducted tax at source from a remittance abroad, it cannot be inferred that the person making the remittance has committed a failure in discharging his tax withholding obligations

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

section 41(1) of the Act amounting to Rs.45,93,627/-. The said additions u/s.41(1) of the Act was made by the Ld. AO due to the reason that no details of the creditors to whom the amount was payable was produced by the assessee before the Ld. AO. 8.1 Feeling aggrieved by the order passed

ANRAK ALUMINIUM LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD

Appeal is partly allowed in foregoing terms

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

Section 14A r.w. Rule 8D(2)(ii) of the Income Tax Rules in arriving proportionate interest expenditure disallowance of Rs.3,37,63,307/-. Case records and more particularly para 3.4 of the assessment order suggests that the assessee was found to have made investments of Rs.17,41,46,612/- relating to its exempt income from dividends to the tune

SHASHIKALA RAM KUMAR ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, appeal of the assessee is allowed in part

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

disallowance of Rs. 63,65,549/- under section 40(a)(ia) of the Act for not affecting TDS in respect of interest and financial charges, and Rs. 2,62,06,238/- under section 40A(3) of the Act for making cash payments in excess of Rs. 20,000/- in contravention of the provisions of law. 3. In appeal, assessee produced

NITIN BHATIA,HYDERABAD vs. ITO., WARD-12(1), HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1472/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Shri Nitin Bhatia Vs. Income Tax Officer Hyderabad Ward 12 (1) Pan:Akqpb1898R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Y.V Bhanu Narayan Rao राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 16/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

234/-, out of which the assessee’s share at 50% worked out to Rs.66,91,617/-. The assessee claimed deduction of the entire long term capital gain under section 54 of the Income Tax Act, 1961 (“the Act”). The assessee had entered into an Agreement of Sale dated 02.03.2018 with M/s Sri Aditya Vamsiram Homes LLP for purchase

DCIT, CENTRAL CIRCLE-3(2), HYD, HYDERABAD vs. PAVITRAVATI GREENFIELDS PRIVATE LIMITED, HYD, HYDERABAD

In the result, appeal of the revenue is treated as partly allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2008-09 Dy. Commissioner Of Vs. Pavitravati Greenfields Income-Tax, P. Ltd., Hyderabad. Central Circle – 3(2), Hyderabad. Pan – Aaecp0216E (Appellant) (Respondent) Revenue By: Shri Y.V.S.T. Sai Assessee By: Shri K.C. Devdas Date Of Hearing: 06/10/2021 Date Of Pronouncement: 04/01/2022

234 B with potential tax effect of Rs. 1.02 crore.” 2.2. Against the Notices u/s 143(2) and 142(1) issued to the assessee calling for information, the AR of the assessee furnished the information called for. After examining the information filed by the assessee and material available on record, the AO finalized the assessment by disallowing an amount

MADHUSUDHAN JAJU,HYDERABAD vs. INCOME TAX OFFICER, WARD-1, SANGAREDDY

In the result, the C.O. of the Revenue is allowed for statistical\npurposes

disallowed the exemption of\nRs.18,14,003/- u/s.54F of the Act. The Ld. AR relying on the\ndecision of Hon'ble High Courts and Tribunals (page nos.1 to 53 of\nthe case laws of paper book) and submitted that even if the amounts\nare invested in CGAS after the due date specified u/s.139(1)\nof the Act, but before filing

ACIT, CENTRAL CIRCLE-2(1), HYDERABAD vs. TRIDENT CHEMPHAR LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Asst. Commissioner Of Income Vs. M/S. Trident Chemphar Ltd. Hyderabad. Tax, Central Circle – 2(1), Pan : Aaeft8416H. Hyderabad. (Appellant) (Respondent) Assessee By: Shri B.G. Reddy Revenue By: Shri Rajendra Kumar – Cit-Dr Date Of Hearing: 09.01.2023 Date Of Pronouncement: 09.01.2023

section is about genesis or accruing or arising in India, by virtue of connection with the property in India, control and management vested in India, which are not satisfied in the present cases. Under these circumstances, withdrawal of earlier circulars issued by the CBDT has no assistance to the Department, in any way, in disallowing such expenditure. It appears that

M/S. COUNTRY CLUB INDIA LTD.,,HYDERABAD vs. ACIT, CIRCLE-1(2), HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

234/- towards Postage & courier charges. 32. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 4,55,600/- towards Recruitment expenses. 33. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 53,84,615/- towards House

DY.CIT, CIR-1(2), HYDERABAD vs. M/S CUNTRY CLUB (I) LIMITED,, HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

234/- towards Postage & courier charges. 32. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 4,55,600/- towards Recruitment expenses. 33. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 53,84,615/- towards House

ACIT., CIRCLE-5(1), HYDERABAD vs. SANJAY CHOWDARY GADDIPATI, HYDERABAD

disallowance of section\n54F of the Act is hereby deleted. Accordingly, Ground No. 1 is allowed.\nThe Revenue being aggrieved with the order of CIT(A) has\ncarried the matter in appeal before us.\n6.\nWe have heard the learned Authorized Representatives of both\nparties, perused the orders of the lower authorities and the\nmaterial available on record, as well

INFOR (INDIA) PRIVATE LIMITED (FORMERLY KNOWN INFOR GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

234(3) OF THE ACT: 12. On the facts and in the circumstances of the case and in law, the Ld. A 0 erred in and the Hon'ble DRP further erred in upholding/confirming the action of the Ld. AO in levying interest uls 2348 of the Act and the said levy of interest being Wholly Unjustified, ought

INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRLCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

234(3) OF THE ACT: 12. On the facts and in the circumstances of the case and in law, the Ld. A 0 erred in and the Hon'ble DRP further erred in upholding/confirming the action of the Ld. AO in levying interest uls 2348 of the Act and the said levy of interest being Wholly Unjustified, ought

ACIT., CENTRAL CIRCLE-2(2), HYDERABAD vs. SRI ADITYA HOMES PRIVATE LIMITED, HYDERABAD

In the result the appeal I

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

disallowed under section 40(A3) of the Act. In respect of balance amount of Rs.98,62,500/- reflected in the loose sheets, it pertains to development of the project in QM Nagar land belongs to Shri K. Raghuram Krishna Raju and the project got held up due to denial of permission by the Archaeological Department and the same

SRIDHAR REDDY BAYAPU,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

Bench: Us:

disallowed. 5.2. The appellant had attached the particulars of payment made for the purchase of a new property along with written submissions dated 27/07/2024. It is seen that a sum of Rs. 1.4 Crs has been paid during the period from 6/6/2015 to 18/11/2015. It is to be noted that subsequent to the sale of property on 31/10/2015, only

ANANTH TECHNOLOGIES LIMITED.,HYDERABAD. vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)., HYDERABAD.

In the result, the appeal of assessee is allowed

Bench: Shri B. Ramakotaiah & Shri Challa Nagendra Prasad

section is about genesis or accruing or arising in India, by virtue of connection with the property in India, control and management vested in India, which are not satisfied in the present cases. Under these circumstances, withdrawal of earlier circulars issued by the CBDT has no assistance to the Department, in any way, in disallowing such expenditure. It appears that

ADALA BHANU REKHA,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.583/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18) Adala Bhanu Rekha Vs. Dcit Hyderabad Circle-6(1) [Pan : Accpa8679F] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Bg Reddy, Ar रधजस् व द्वधरध/Revenue By:: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 25/11/2024 घोर्णध की तधरीख/Date Of 05/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31/03/2024 Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)], National Faceless Appeal Centre (Nfac), Delhi, Relating To A.Y.2017-18 On The Following Grounds :

section and issue of notice u/s 148 is valid in law. 3. The learned CIT (Appeals) failed to note that all the information/ particulars/details were already furnished by the Appellant at the time of assessment proceedings itself and in the absence of any fresh/ new information, reopening of the assessment by mere changing the opinion

AMARA RAJA POWER SYSTEMS LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

Section 194C\nof the Act. Also, it was the claim of the assessee company that\namong the other expenses, some of the major expenses\naggregating to Rs.2,37,49,913.69 were incurred towards expenses\nthat were not liable for deduction of tax at source, viz. (i). travel\nexpenses of staff; (ii). travel fare (air); (iii). travel fare (train); (iv).\nother