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

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 COOPERATIVE BANK LIMITED,HYDERABAD vs. ASST.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-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

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

section 234B/234C, which was disallowed in the earlier years.\n2. An amount of Rs.2,09,08,248/- was credited to Profit and Loss Account in F.Y. 2017-18 towards the reversal of excess interest debited in earlier years, computed as under:\nSr\nInterest\nrelating\nto A.Y.\n(1)\nInterest\nDetermined\non\n(2)\nInterest\ndebited\nto P&L\nA/c

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

Section 234B/234C, which\nwas disallowed in the earlier years.\n2. An amount of Rs.2,09,08,248/- was credited to Profit and Loss Account in F.Y. 2017-18\ntowards the reversal of excess interest debited in earlier years, computed as under:\nSr\nInterest\nrelating\nto A.Y.\n(1)\n(2)\nInterest\nDetermined\non\n(3)\nInterest\ndebited

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

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, three appeals i

disallowed on a technical reason of delay in\nfiling of the Audit Report in Form No. 10B, which is due to\na reasonable cause and the same is beyond the control of\nthe appellant.\nThe Ld. CIT(A) has erred in observing that the appellant\nhas not given any reasonable cause for delay in filing the\nappeal by over

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

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

disallowed on a technical reason of delay in\nfiling of the Audit Report in Form No. 10B, which is due to\na reasonable cause and the same is beyond the control of\nthe appellant.\n4.\nThe Ld. CIT(A) has erred in observing that the appellant\nhas not given any reasonable cause for delay in filing the\nappeal by over

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

disallowed on a technical reason of delay in\nfiling of the Audit Report in Form No. 10B, which is due to\na reasonable cause and the same is beyond the control of\nthe appellant.\n4.\nThe Ld. CIT(A) has erred in observing that the appellant\nhas not given any reasonable cause for delay in filing the\nappeal by over

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

disallowed on a technical reason of delay in\nfiling of the Audit Report in Form No. 10B, which is due to\na reasonable cause and the same is beyond the control of\nthe appellant.\n4.\nThe Ld. CIT(A) has erred in observing that the appellant\nhas not given any reasonable cause for delay in filing the\nappeal by over

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

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