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

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

disallowed the claim of deduction, inter-alia, on the ground that a claim not made in the original return filed under Section 139(1) and sought to be made for the first time in a return filed pursuant to a notice under Section 153A of the Act would not be maintainable. Further, the assessee was also found to be ineligible

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

disallowed U/s.40A(3) and is added to the total income of the assessee. 14.1 On appeal, the ld.CIT(A) had decided the issue at pages 70 to 74 of the order wherein he observed as under : “The claim of the appellant that the payments have been made by the M/s. DLF group is false and completely unsubstantiated and no confirmation

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. 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

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

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

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

JASPER INDUSTRIES PVT LTD,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

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

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

4. The A.O. called upon the assessee to explain as to why disallowance should not be made under Section 14A read with Rule 8D of the Act in respect of expenditure allegedly incurred for earning exempt dividend income. In response, the assessee submitted that it has not incurred any direct expenditure for earning the dividend income and that the investments

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

4. Rachna Infrastructure (P.) Ltd. [2022] 138 taxmann.com 416 (Gujarat) 5. NEC NCC Maytas JV Vs. DCIT – ITA Nos. 430 to 432/Hyd/2016 and others. 6. Katira Construction Ltd. Vs. Union of India – (2013) 31 taxmann.com 250 Gujarat 7 PCIT and another Vs. M/s. Wipro Limited – Civil Appeal No.1449 of 2022 arising out of SLP (Civil) No.7620/2021

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

4. Rachna Infrastructure (P.) Ltd. [2022] 138 taxmann.com 416 (Gujarat) 5. NEC NCC Maytas JV Vs. DCIT – ITA Nos. 430 to 432/Hyd/2016 and others. 6. Katira Construction Ltd. Vs. Union of India – (2013) 31 taxmann.com 250 Gujarat 7 PCIT and another Vs. M/s. Wipro Limited – Civil Appeal No.1449 of 2022 arising out of SLP (Civil) No.7620/2021

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

4. Rachna Infrastructure (P.) Ltd. [2022] 138 taxmann.com 416 (Gujarat) 5. NEC NCC Maytas JV Vs. DCIT – ITA Nos. 430 to 432/Hyd/2016 and others. 6. Katira Construction Ltd. Vs. Union of India – (2013) 31 taxmann.com 250 Gujarat 7 PCIT and another Vs. M/s. Wipro Limited – Civil Appeal No.1449 of 2022 arising out of SLP (Civil) No.7620/2021

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

4. Rachna Infrastructure (P.) Ltd. [2022] 138 taxmann.com 416 (Gujarat) 5. NEC NCC Maytas JV Vs. DCIT – ITA Nos. 430 to 432/Hyd/2016 and others. 6. Katira Construction Ltd. Vs. Union of India – (2013) 31 taxmann.com 250 Gujarat 7 PCIT and another Vs. M/s. Wipro Limited – Civil Appeal No.1449 of 2022 arising out of SLP (Civil) No.7620/2021

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

4 6. The brief facts of the case are that the assessee is a company which filed its return of income for the Assessment Year 2016–17 on 13.10.2016, declaring total income of Rs.2,96,250/-. The case of the assessee was reopened under section 147 of the Income Tax Act, 1961 (“the Act”), and accordingly, a notice under section

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

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELCOM INFRASTRUTURE PRIVATE LIMITED , HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

Section 250(4).. There may be cases where additional evidence is admitted by the first appellate authority on a request or application being made by the assessee. In such cases Sub-rule (2) of rule 46A requires the first appellate authority to allow the assessing officer a further opportunity to rebut the fresh evidence filed by the assessee. Even that