INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 2348 and 234D of the Act. The aforesaid grounds are independent and without prejudice to each other. The Appellant craves leave to add, alter, amend, modify or withdraw all or any of the Grounds of Appeal contained herein as may be considered necessary either before or during the hearing of the appeals. The Appellant prays that directions be given

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

234D of the Act while calculating the Appellant's\npayable demand.\nInitiation of penalty under Section 270A\n11. On the facts and circumstances of the case and in law, the Id. AO\nerred in initiating penalty proceedings under Section 270A of the\nAct.\n5\nITA.Nos.125 & 474/Hyd./2022\nThe above grounds are independent and without prejudice to one\nanother

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

234D of the Act while calculating the Appellant's payable demand. Initiation of penalty under Section 270A 11. On the facts and circumstances of the case and in law, the Id. AO erred in initiating penalty proceedings under Section 270A of the Act. 5 ITA.Nos.125 & 474/Hyd./2022 The above grounds are independent and without prejudice to one another

UBER INDIA SYSTEMS PRIVATE LIMITED (AS SUCCESSOR TO UBER INDIA RESEARCH AND DEVELOPMENT PRIVATE LIMITED),HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Disallowed 13. On the facts and in circumstances of the case and in law, the learned TPO erred, and Hon'ble DRP further erred in upholding/confirming the action of the learned TPO in not allowing the risk adjustment in accordance with the Rules to account for difference between the risk profile of the Appellant and that of alleged comparable companies

VENKATESH DAGGUBATI,HYDERABAD vs. DCIT, CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee is dismissed

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

disallowances and the principles of natural justice. 10. The Learned assessing officer and Commissioner of Income Tax, Appeals erred in charging/ upholding interest under section 234D

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

In the result, the appeals filed by the assessee is partly allowed\nfor statistical purposes

disallowed.\n1.5\nThe AO/ DRP ought to have appreciated that taxes are levied on profits whereas 'cess'\nis levied only on taxes and not profits and as such 'cess' is not covered within the meaning\nof taxes under section 40(a)(ii) of the Act.\n1.6\nThe AO / DRP ought to have appreciated that cess cannot be construed

VIJAYAWADA TOLLWAY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal filed by the assessee is\nOrder pronounced in the Open Court on 6th February, 2026

disallowance of\nexpenditure resulted in enhancement of income and therefore, the\nLd. AO was justified in initiating and levying penalty under section\n271(1)(c) of the Act.\n7.\nWe have carefully considered the rival submissions\nand perused the material available on record. We have also gone\nthrough page no. 8 of the reassessment order dated 05.12.2019\npassed

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

ACE CONSTRUCTIONS,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ACE CONSTRUCTIONS,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -3(4), HYDERABAD vs. ROYAL ENGINEERING, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -3(4), HYDERABAD vs. ROYAL ENGINEERING, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ROYAL ENGINEERING, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ROYAL ENGINEERING, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ACE CONSTRUCTIONS , HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ACE CONSTRUCTIONS, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ACE CONSTRUCTIONS, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ACE CONSTRUCTIONS, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place

ROYAL ENGINEERING,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

disallowance on merits. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has erred in invoking the provisions of section 153C of the Act to the year under reference which is beyond the period Page 2 of 31 of six years preceding the financial year in which the search took place