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

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

disallowance under section 14A of the Act read with rule 8D of the Income Tax Rules, 1962 (‘the Rules’). This action of the learned CIT(A) is challenged by the assessee under grounds 3 to 11 of this appeal. 15. Apart from this, learned CIT(A) also considered the addition on account of long term capital loss. She agreed with

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

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

disallowance under section 14A of the Act read with rule 8D of the Income Tax Rules, 1962 (‘the Rules’). This action of the learned CIT(A) is challenged by the assessee under grounds 3 to 11 of this appeal. 15. Apart from this, learned CIT(A) also considered the addition on account of long term capital loss. She agreed with

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

250/-. The case of the assessee was reopened under section 147 of the Income Tax Act, 1961 (“the Act”), and accordingly, a notice under section 148 of the Act was issued by the Learned Assessing Officer (“Ld. AO”) on 12.03.2021. During the course of reassessment proceedings, the assessee filed its reply on 12.01.2022, enclosing copies of the books of account

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

disallowing 50% of the expenditure, despite TPO accepting similar expenditure to be at arm's length to the extent of its actual cost in subsequent assessment year (AY 2022-23) 5. The lower authorities have erred in making an adjustment towards interest on loans advanced to subsidiaries despite the fact that, under the terms of the loan agreement, no interest

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

disallowing 50% of the expenditure, despite TPO accepting similar expenditure to be at arm's length to the extent of its actual cost in subsequent assessment year (AY 2022-23) 5. The lower authorities have erred in making an adjustment towards interest on loans advanced to subsidiaries despite the fact that, under the terms of the loan agreement, no interest

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

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

disallowed in the previous year. 7 ITA.Nos.125 & 474/Hyd./2022 Investment allowance under Section 32AD 8. On the facts and circumstances of the case and in law, the Id. AO, under the direction of the Hon'ble DRP, erred in not appreciating that the Appellant ought to be granted investment allowance as per Section 32AD of the Act. Initiation

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.917/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2020-21) Shakti Hormann Private Limited, Hyderabad. Vs. Dcit, Circle-3(1), Hyderabad. Pan: Aadcs4024Q (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 15/10/2025 घोषणा की तारीख / Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Final Assessment Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The

disallowances; and (vii) prior year adjustments. After necessary verifications, the AO accepted the assessee's explanation on the issues other than the TP adjustment that was suggested by the TPO. 6. The AO thereafter issued a draft assessment order under section 144C(1) of the Act, dated 26/09/2023, wherein, after incorporating the TP adjustments, he proposed to assess the income

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

disallowing for the market risk adjustment to eliminate the difference in the risk level of the Appellant and the comparable companies. 3:3 The Appellant submits that the learned AO/TPO be directed to recalculate the adjustment made by him to the Appellant's total income and to re-compute its total income and tax liability accordingly. 4:0 Transfer Pricing

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

disallowing for the market risk adjustment to eliminate the difference in the risk level of the Appellant and the comparable companies. 3:3 The Appellant submits that the learned AO/TPO be directed to recalculate the adjustment made by him to the Appellant's total income and to re-compute its total income and tax liability accordingly. 4:0 Transfer Pricing

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Section 14A of the Act, as was available on the statute before its amendment vide the Finance Act, 2022 w.e.f 01.04.2022, in the absence of receipt of any exempt income no disallowance u/s 14A of the Act could have been made in the hands of the assessee company. Our aforesaid view is fortified by the judgment

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आयकर अपीलसं./I.T.A. No.1083/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2017-18) Assistant Commissioner Of Income Tax, Circle-5(1), Hyderabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) Industries आयकर अपीलसं./I.T.A. No.1084/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2018-19) Assistant Commissioner Of Income Tax, Circle-5(1), Hydeabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Industries Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By : Shri Sourabh Soparkar, Advocate राजस्वकाप्रतिनिधित्व/ Department Represented By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing : 11/11/2025 घोषणा की तारीख/ Date Of Pronouncement : 21/01/2026 2

Section 14A of the Act, as was available on the statute before its amendment vide the Finance Act, 2022 w.e.f 01.04.2022, in the absence of receipt of any exempt income no disallowance u/s 14A of the Act could have been made in the hands of the assessee company. Our aforesaid view is fortified by the judgment

ASIAN INSTITUTE OF GASTROENTEROLOGY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2020-2021 and 2021-2022 are allowed

Bench: Shri Manjunatha G & Shri Ravish Sood

disallowance under section 14A read with Rule 8D of I.T. Rules, 1962. Therefore, in our considered view, where the Assessing Officer has taken a 18 ITA.Nos.609 & 610/Hyd./2025 plausible view on the issue, after considering relevant submissions of the assessee, then, the learned PCIT cannot substitute his views on the very same issue, unless, the view taken

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. DCIT., CIRCLE-13(1), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.283, 284 & 286/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं / Ita Nos.300, 301 & 308/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. Cit, Circle 13(1) Hyderabad Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 10/06/2025 घोषणा की तारीख / Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

Section 37 of the Income Tax Act, 1961. 4. Your Appellant submits that the CIT(A) as well as the Assessing Officer ignored the fact that the payments made to Singareni Educational Society in the past have been allowed as business expenditure u/s 37, ought not to have disallowed Rs. 41,08,54,250

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

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

250 with reference to section 143(3) r.w.s. 263 of the Income Tax Act 1961, no grounds pertaining to section 80IA was raised by the assessee before the Tribunal. 17. The Tribunal vide order dt. 28.12.2012 had disposed of various appeals filed by the assessee for various assessment years. The Tribunal had granted the relief to the assessee by remanding

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

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

250 with reference to section 143(3) r.w.s. 263 of the Income Tax Act 1961, no grounds pertaining to section 80IA was raised by the assessee before the Tribunal. 17. The Tribunal vide order dt. 28.12.2012 had disposed of various appeals filed by the assessee for various assessment years. The Tribunal had granted the relief to the assessee by remanding

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

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

250 with reference to section 143(3) r.w.s. 263 of the Income Tax Act 1961, no grounds pertaining to section 80IA was raised by the assessee before the Tribunal. 17. The Tribunal vide order dt. 28.12.2012 had disposed of various appeals filed by the assessee for various assessment years. The Tribunal had granted the relief to the assessee by remanding

APEX URBAN INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(3), HYDERABAD

Accordingly, we herein direct the AO to vacate the disallowance of Rs. 13,200/- made by him. The Grounds of appeal Nos. 2 and 3 are allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1778/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Apex Urban Infrastructure Vs. Dcit, Private Limited, Central Circle-2(3), Hyderabad. Hyderabad. Pan: Aafcp1027Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Date Of 13/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals)- 12, Hyderabad, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 31/10/2019 For The Assessment Year (Ay) 2017-18. The Assessee Company Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal Before Us:

disallowance under section 14A of the Act. The Ld. AR in support of his aforesaid contention had relied upon the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Chettinad Logistics (P.) Ltd (2018) 95 taxmann.com 250