ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

disallowance of business support service expense of INR 75,91,57,538 for non-deduction of Tax Deducted at Source ('TDS') under section 40(a)(i) of the Act. 2.2 Additionally, on the facts and circumstances of the case, and contrary to the law, the Ld. AO erred. and the Hon'ble DRP further erred in: 3 ADP Private Limited

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowance made by Ld. AO by not appreciating the fact that the Parliament intended certain restrictions to only CSR expenditure in respect of two donations namely Swachh Bharat Kosh and Clean Ganga Fund and has impliedly not made any prohibition/restriction in respect of claim of CSR expenses in other cases if it is otherwise eligible under section

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 11 is already considered in the regular assessment and that issue is already in appeal before FAA. Therefore, reviewing the same is uncalled for.” 8. Accordingly, in view of the above cited judgement of the Hon'ble Allahabad High Court as well as the decision of the Delhi Benches of the Tribunal, we hold that the processing

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

disallowing the relief claimed by the Appellant of INR 31,48,038 towards foreign tax credits under section 90/91 of the Act, without considering assessee's submission and documentary evidence. 19. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in disregarding Assessee's claim for additional relief

FEDERATION OF AP COOPERATIVE URBAN BANKS AND CREDIT SOCIETIES LIMITED HYD,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.464/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Federation Of Ap Vs. Income Tax Officer Cooperative Urban Banks Ward 9(1) & Credit Societies Ltd. Hyderabad Hyd, Hyderabad Pan:Aaaaf7350F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri V. Ravish Bhatt, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 29/10/2025 घोषणा की तारीख/Pronouncement: 07/11/2025

disallowance of the deduction of Rs. 36,70,431/- claimed u/s 80P of the Act is not justified. 4. Further, without prejudice to Ground No. 2 and Ground No. 3 the income of the appellant is exempt as per the ‘Principle of Mutuality’ and hence the same is not liable tax. 5. Charging of interest

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

disallowance of Rs.45,90,60,000 are incorrect and cannot be sustained.” 2.1. Thereafter, assessee has filed the following additional grounds which read as under : “1. The ld.AO and ld.CIT(A) have erred in making addition / sustaining addition of Rs.27,09,00,000/- in respect of unsold balance lands of Ac.6.18 guntas to Sri S. Narayana Reddy and others

NEKKANTI SEA FOODS LTD, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-16(1), HYDERABAD, HYDERABAD

In the result, assessee’s appeals are partly allowed for statistical purposes

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

234B of the I.T. Act without considering the fact that the tax arose on account of retrospective amendment brought in. 4. Any other ground or grounds that may be urged at the time of hearing”. 2. Further, the assessee has also raised the following additional grounds of appeal: “The AO erred in excluding the income from the DEPB license

NEKKANTI SEA FOODS LTD., HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-16(1), HYDERABAD, HYDERABAD

In the result, assessee’s appeals are partly allowed for statistical purposes

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

234B of the I.T. Act without considering the fact that the tax arose on account of retrospective amendment brought in. 4. Any other ground or grounds that may be urged at the time of hearing”. 2. Further, the assessee has also raised the following additional grounds of appeal: “The AO erred in excluding the income from the DEPB license

NEKKANTI SEA FOODS LTD, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-16(1), HYDERABAD, HYDERABAD

In the result, assessee’s appeals are partly allowed for statistical purposes

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

234B of the I.T. Act without considering the fact that the tax arose on account of retrospective amendment brought in. 4. Any other ground or grounds that may be urged at the time of hearing”. 2. Further, the assessee has also raised the following additional grounds of appeal: “The AO erred in excluding the income from the DEPB license

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 143(3) r/w 153A on 31.03.2013 for the A.Y. 2005-06 and 2006-07. However, in both the orders, the Assessing Officer has not given any deduction claimed by the assessee. In the assessment order dt.31.03.2013 mentioned as under : “Search and seizure operations u/s. 132 of the I.T. Act, 1961 were carried out in the case of M/.s. Madhucon

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 143(3) r/w 153A on 31.03.2013 for the A.Y. 2005-06 and 2006-07. However, in both the orders, the Assessing Officer has not given any deduction claimed by the assessee. In the assessment order dt.31.03.2013 mentioned as under : “Search and seizure operations u/s. 132 of the I.T. Act, 1961 were carried out in the case of M/.s. Madhucon

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 143(3) r/w 153A on 31.03.2013 for the A.Y. 2005-06 and 2006-07. However, in both the orders, the Assessing Officer has not given any deduction claimed by the assessee. In the assessment order dt.31.03.2013 mentioned as under : “Search and seizure operations u/s. 132 of the I.T. Act, 1961 were carried out in the case of M/.s. Madhucon

VK WAREHOUSING ENTERPRISES,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

3,11,24,473 under section(u/s) 37(1) of the Income-tax Act, 1961 (the Act) , without proper verification of the relevant records and supporting documents. 4. The Hon’ble CIT(A) erred in sustaining the addition of INR 25,85,800 made by the Ld.AO u/s 69 of the Act, by treating the cash deposits as unexplained, without

ACIT., CIRCLE-6(1), HYDERABAD vs. VK WAREHOUSING ENTERPRISES, HYDERABAD

In the result, both the appeals filed by the assessee firm and

3,11,24,473 under section(u/s) 37(1) of the Income-tax Act, 1961 (the Act) without proper verification of the relevant records and supporting documents. , 4. The Hon'ble CIT(A) erred in sustaining the addition of INR 25,85,800 made by the Ld.AO u/s 69 of the Act, by treating the cash deposits as unexplained, without

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

disallowance of the deduction under section 80G of the Act, besides TDS short credit and interest under section 234B and 234C of the Act. Apart from these, there were certain other issues including the transfer pricing adjustment qua the provision of IT services. 3

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

disallowance of the deduction under section 80G of the Act, besides TDS short credit and interest under section 234B and 234C of the Act. Apart from these, there were certain other issues including the transfer pricing adjustment qua the provision of IT services. 3

THERMODYNE DYNAMICS PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD -17(3), HYDERABAD

Bench: Us :

3. Whether the learned Authorities below are justified in disallowing Rs. 15,75,000/- on investments an amount being Rs, 31,50,00,000/-, under the facts and circumstances of the case. 4. Whether the learned Authorities below are justified in disallowing Rs. 15,75,000/-under section 14A of the Act, under the facts and circumstances of the case

PITTI HOLDINGS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

disallowances of expenditure are not sustainable in law and liable to be deleted. In support of his contention, he has relied upon the judgment of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways (I) Ltd. 331 ITR 236 (Bom). 7. On the other hand, the Ld. DR has submitted that the Assessing Officer has followed

ELEM INVESTMENTS P. LTD., HYD,HYDERABAD vs. ACIT, CENTRAL CIRCLE-8, HYD, HYDERABAD

In the result, all the appeals under consideration are dismissed

Bench: Shri A. Mohan Alankamony & Shri V. Durga Rao

3,08,059/-, by giving a relief to the assessee of Rs. 2,58,059/-. 10.3 After considering the rival submissions and material on record, we find no infirmity in the decision of the CIT(A) in restricting the disallowance to Rs. 50,000/- and accordingly, we uphold the order of CIT(A) on this issue and dismiss the ground