ASST. DIRECTOR OF IT (EXEMP)-II,, HYDERABAD vs. ACTION FOR WELFARE AND AWAKENING IN RURAL ENVIRONMENT (AWARE), HYDERABAD

In the result, the C.O. filed by the assessee is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.709/Hyd/2012 ("नधा"रण वष"/Assessment Year:1995-96) Asst. Director Of Income Tax Vs. Action For Welfare & (Exemptions)-Ii, Awakening In Rural Hyderabad. Environment (Aware), Shantivanam, Nagarjuna Sagar Road, Hyderabad. Pan: Aaata2338R (Appellant) (Respondent) C.O. No.138/Hyd/2012 (In आ.अपी.सं /Ita No.709/Hyd/2012) ("नधा"रण वष"/Assessment Year:1995-96) Asst. Director Of Income Tax Vs. Action For Welfare & (Exemptions)-Ii, Awakening In Rural Hyderabad. Environment (Aware), Pragati Bhavan, D.No.5-9- 24/78, Lake Hill Road, Adarshnagar, Hyderabad- 500463. Pan: Aaata2338R (Respondent/Cross Objector) (Appellant In Appeal) "नधा"रती "वारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "वारा/Revenue By:: Ms. U. Mini Chandran, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing: 08/01/2026 घोषणा क" तार"ख/Pronouncement: 13/02/2026

254 of the Act on 26.03.2004, assessing the total income of the assessee at Rs.13,76,58,674/-, mainly by invoking section 11(3) of the Act. 3. Aggrieved with the order of the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A), after considering the submissions of the assessee, deleted the entire

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

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

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

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

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

2% on total advertisement expenses of Rs. 1,50,000/- and the same has been deposited into the Government account. In respect of interest on TDS, the learned counsel for the assessee submitted that, it is not an item to be disallowed under Section 40(a)(ia) of the Act. Although these facts are explained

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee for A

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

2% on total advertisement expenses of Rs. 1,50,000/- and the same has been deposited into the Government account. In respect of interest on TDS, the learned counsel for the assessee submitted that, it is not an item to be disallowed under Section 40(a)(ia) of the Act. Although these facts are explained

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

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

2% on total advertisement expenses of Rs. 1,50,000/- and the same has been deposited into the Government account. In respect of interest on TDS, the learned counsel for the assessee submitted that, it is not an item to be disallowed under Section 40(a)(ia) of the Act. Although these facts are explained

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

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

disallowed in the previous year.\nInvestment allowance under Section 32AD\n8. On the facts and circumstances of the case and in law, the Id. AO,\nunder the direction of the Hon'ble DRP, erred in not appreciating\nthat the Appellant ought to be granted investment allowance as per\nSection 32AD of the Act.\nInitiation of penalty under Section 270A

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

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

disallowance under Section 40(a)(ia), and addition towards Form 26AS mismatch. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Shri Sriram Seshadri, C.A., referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.12.2024, submitted

INCOME TAX OFFICER, WARD-3 (1), HYDERABAD vs. REGENCY CERAMICS LIMITED, HYDERABAD

In the result, appeal filed by the Revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

Bench: Us:

2) of section 80IA is to be reduced from the “book profits”. It was, thus, the claim of the assessee company that while computing the “book profit” U/s. 115JA it had claimed deduction under Section 80IA r.w.s 33B of the Act. Thereafter, the A.O. framed the set-aside assessment vide his order passed under Section 143(3) r.w.s 254

INCOME TAX OFFICER, WARD-3(1), HYDERABAD vs. REGENCY CERAMICS LIMITED, HYDERABAD

In the result, appeal filed by the Revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

Bench: Us:

2) of section 80IA is to be reduced from the “book profits”. It was, thus, the claim of the assessee company that while computing the “book profit” U/s. 115JA it had claimed deduction under Section 80IA r.w.s 33B of the Act. Thereafter, the A.O. framed the set-aside assessment vide his order passed under Section 143(3) r.w.s 254

INCOME TAX OFFICER, WARD-3(1), HYDERABAD vs. REGENCY CERAMICS LIMITED, HYDERABAB

In the result, appeal filed by the Revenue being devoid and bereft\nof any substance is dismissed in terms of our aforesaid observations

2) of section\n80IA is to be reduced from the “book profits”. It was, thus, the claim of\nthe assessee company that while computing the “book profit" U/s.\n115JA it had claimed deduction under Section 80IA r.w.s 33B of the\nAct. Thereafter, the A.O. framed the set-aside assessment vide his order\npassed under Section 143(3) r.w.s 254

INCOME TAX OFFICER, WARD-3(1), HYDERABAD vs. REGENCY CERAMICS LIMITED, HYDERABAD

In the result, appeal filed by the Revenue being devoid and bereft\nof any substance is dismissed in terms of our aforesaid observations

2) of section\n80IA is to be reduced from the “book profits”. It was, thus, the claim of\nthe assessee company that while computing the “book profit" U/s.\n115JA it had claimed deduction under Section 80IA r.w.s 33B of the\nAct. Thereafter, the A.O. framed the set-aside assessment vide his order\npassed under Section 143(3) r.w.s 254

INCOME TAX OFFICER, WARD-3(1), HYDERABAD vs. REGENCY CERAMICS LIMITED, HYDERABAD

In the result, appeal filed by the Revenue being devoid and bereft\nof any substance is dismissed in terms of our aforesaid observations

2) of section\n80IA is to be reduced from the “book profits”. It was, thus, the claim of\nthe assessee company that while computing the “book profit\" U/s.\n115JA it had claimed deduction under Section 801A r.w.s 33B of the\nAct. Thereafter, the A.O. framed the set-aside assessment vide his order\npassed under Section 143(3) r.w.s 254

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

KRISHNA KISHORE REDDY MANYAM ,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(4) , HYDERABAD

In the result, the appeal filed by the assessee is partly allowed\nfor statistical purposes in terms of our aforesaid observations

disallowed the same.\n5. Ostensibly, the assessee during the course of the assessment\nproceedings came up with a new claim, wherein based on a revised\nstatement of computation of income that was filed with the A.O.\non 29.08.2010, it was claimed by him that as the agricultural land\nsituated at Village: Manchirevula was not a “capital asset” within\nthe meaning

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowance of donations under Section 80G towards CSR expenditure. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Ms. Tanmayee Rajkumar, Advocate, referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.06.2024, submitted that, the assessment