THE ANDHRA PRADESH STATE CO OPERATIVE BANK LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/-, written off under the Agricultural Debt Waiver and Debt Relief Scheme, 2008 (ADWDRS) are debts written off, ignored the directions of the ITAT that provisions of section 37(viia) r.w.s 36(2)(v)A are applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/-, written off under the Agricultural Debt Waiver and Debt Relief Scheme, 2008 (ADWDRS) are debts written off, ignored the directions of the ITAT that provisions of section 37(viia) r.w.s 36(2)(v)A are applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/-, written off under the Agricultural Debt Waiver and Debt Relief Scheme, 2008 (ADWDRS) are debts written off, ignored the directions of the ITAT that provisions of section 37(viia) r.w.s 36(2)(v)A are applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/-, written off under the Agricultural Debt Waiver and Debt Relief Scheme, 2008 (ADWDRS) are debts written off, ignored the directions of the ITAT that provisions of section 37(viia) r.w.s 36(2)(v)A are applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/-, written off under the Agricultural Debt Waiver and Debt Relief Scheme, 2008 (ADWDRS) are debts written off, ignored the directions of the ITAT that provisions of section 37(viia) r.w.s 36(2)(v)A are applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX , HYDERABAD

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

disallowance of deduction u/s 35(2AB) for an amount of Rs.27,69,82,420/- stating that assessee has not produced Form 3CL and form 3CM. The assessee contended that the R & D facility was duly approved by the competent authority and relevant certificates were produced before the AO. 2.5.2 Having considered the submissions, we are of the view that

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

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

disallowance of deduction u/s 35(2AB) for an amount of Rs.27,69,82,420/- stating that assessee has not produced Form 3CL and form 3CM. The assessee contended that the R & D facility was duly approved by the competent authority and relevant certificates were produced before the AO. 2.5.2 Having considered the submissions, we are of the view that

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

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

disallowance of deduction u/s 35(2AB) for an amount of Rs.27,69,82,420/- stating that assessee has not produced Form 3CL and form 3CM. The assessee contended that the R & D facility was duly approved by the competent authority and relevant certificates were produced before the AO. 2.5.2 Having considered the submissions, we are of the view that

VIVIMED LABS LIMITED,HYDERABAD vs. 500082 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

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

disallowance of deduction u/s 35(2AB) for an amount of Rs.27,69,82,420/- stating that assessee has not produced Form 3CL and form 3CM. The assessee contended that the R & D facility was duly approved by the competent authority and relevant certificates were produced before the AO. 2.5.2 Having considered the submissions, we are of the view that

SKYBRIDGE SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, (TP)-2 HYDERBAD, HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar(Through Virtual Mode) & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2021-22 Skybridge Solutions Vs. The Deputy Commissioner Of Private Limited, Income Tax, Hyderabad, (Transfer Pricing)-2, H.No.8-2-239/L/83-A, Hyderabad. Plot No.83/A, Mla Colony, Road No.12, Banjara Hills, Hyderabad – 500034, Telangana. Pan : Aalcs1899M. (Appellant) (Respondent) Assessee By: Shri Mahesh Raichandani, C.A. Revenue By: Ms. K. Haritha, Cit-Dr Date Of Hearing: 23.04.2024 Date Of Pronouncement: 29.04.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2021-22 Arises From The Impugned Assessment Order Passed U/S 143(3) R.W.S. 144C(3) R.W.S. 144B Of The Income Tax Act Dated 26.12.2023. 2. The Brief Facts Of The Case Are That The Assessee Is A Software Development & Services Company, Filed Its Income Tax Return For The Assessment Year 2021-22 On 09.03.2022, Declaring A Total Income Of Rs.1,06,49,030. The Return Was Processed Under Section 143(1)(A) Of The Income Tax Act On 24.08.2022. Subsequently, The Case Was Selected For Scrutiny Under Cass & A Notice Under Section 143(2) Was Issued On 28.06.2022, To Which The Assessee Responded On 15.07.2023. Thereafter, A Reference Under Section 92Ca(1) Was Made To The Transfer Pricing Officer (Tpo) To Determine The Arm'S Length Price For Transactions With Associated Enterprises. The Tpo, Through An Order Dated 31.10.2023, Directed An Upward Adjustment Of Rs.1,83,25,993 To The Assessee'S Income For The Financial Year 2020-21. Consequently, A Show Cause Notice Was Issued To The Assessee On November 9, 2023, Regarding The Proposed Adjustment, Along With A Penalty Initiation Under Section 270A.

disallowance, but again, no response was forthcoming. Consequently, the draft assessment order was passed on 22.11.2023 proposing the total income at Rs. 2,98,36,480/-. The assessee was given 30 days to either accept the proposed variation or file objections with the DRP. However, no communication was received from the assessee within the stipulated timeframe. Hence, it was assumed

LAMPEX ELECTRONICS LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

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

253(2) of the Income Tax Act, 1961 (for short “the Act”) in the Office of the learned Assessing Officer on 20/01/2021 whereas the appeal was to be filed on 10/11/2020 since the order of the Learned CIT(A) was received on 11/09/2020. Apart from this, circumstances under covid pandemic was also taken shelter by the Revenue. There

ACIT, CIRCLE-5(1), HYDERABAD vs. LAMPEX ELECTRONICS LIMITED , HYDERABAD

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

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

253(2) of the Income Tax Act, 1961 (for short “the Act”) in the Office of the learned Assessing Officer on 20/01/2021 whereas the appeal was to be filed on 10/11/2020 since the order of the Learned CIT(A) was received on 11/09/2020. Apart from this, circumstances under covid pandemic was also taken shelter by the Revenue. There

AGRO TECH FOODS LIMITED., SEC'BAD,SECUNDERABAD vs. DCIT, CIRCLE-1(1), HYD, HYDERABAD

In the result, appeal in ITA No

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singh

disallowed the balance being Rs.6,93,37,003/- and accordingly brought it to tax. 2.2. Subsequently, the CIT (IT & TP) assuming powers u/s 263 of the I.T. Act, perused the TPO’s order and observed that the order passed by the TPO is erroneous in so far as it is prejudicial to the interest of the revenue. He observed that

SUMATHI CORPORATE SERVICES PRIVATE LIMITED,HYDERABAD vs. ITO WARD-3(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

253/-. In the course of assessment proceedings, the Assessing Officer noticed from the Tax Audit Report (TAR) (Col.20(b)) that the assessee had received a sum of Rs. 1,67,86,940/- from its employees as contribution to PF and ESI which was not credited to the employees a/c on or before the due date under the respective law. Accordingly

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

disallowance towards TDS and VAT payable under section 43B of the Act: Rs. 6,08,694/-; and (v) addition of Rs.3,34,246/- on account of estimated profit on undisclosed sales: Rs.3,34,246/-, but at the same time declined the assessee’s claim regarding the validity of jurisdiction that was assumed by the AO, while initiating proceedings under section

JASPER AUTO SERVICES PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2014-15 Jasper Auto Services Pvt. Vs. Dy. Commissioner Of Ltd., Hyderabad. Income-Tax, Circle – 2(1), Hyderabad. Pan – Aaccb 0196P (Appellant) (Respondent)

section 2(42C) of the Act. 3 (a) The Ld. CIT(A) erred in confirming the disallowance 0 expenditure to the extent of Rs.12,14,253/- (b) The ld. CIT (A) ought to have appreciated that the agreement of the assessee's AR for the disallowance of Rs. 12,14,253/-, during the course of assessment proceedings, has not been

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE-1(4), HYDERABAD vs. MEDHA SERVO DRIVES PRIVATE LIMITED, HYDERABAD

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

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

section 28(iv) of the Income-tax Act, 1961 ?" The Hon’ble Supreme Court has observed as under: “3. This Court in Sahney Steel & Press Works Ltd. v. CIT [1997] 228 ITR 253 1 (SC) has held that power subsidies are of revenue nature and have to be taxed accordingly. We also find that the terms under which the subsidy

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE-1(4), HYDERABAD vs. MEDHA SERVO DRIVES PRIVATE LIMITED, HYDERABAD

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

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

section 28(iv) of the Income-tax Act, 1961 ?" The Hon’ble Supreme Court has observed as under: “3. This Court in Sahney Steel & Press Works Ltd. v. CIT [1997] 228 ITR 253 1 (SC) has held that power subsidies are of revenue nature and have to be taxed accordingly. We also find that the terms under which the subsidy