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

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. 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

NICHINO INDIA PRIVATE LIMITED (FORMERLY NICHINO CHEMICAL INDIA PRIVATE LIMITED NOW MERGED),HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.366/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2020-21) Nichino India Private Dcit / Acit Limited (Formerly Nichino Vs. Circle-5(1) Chemical India Private Hyderabad Limited, Now Merged) Hyderabad [Pan : Aaecn5394B] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent धििााररती द्वारा/Assessee By: Ms.Suvibha Nolkha, Ar राजस्‍व द्वारा/Revenue By : Shri D.Praveen, Dr सुिवाई की तारीख/Date Of Hearing: 09/09/2024 घोर्णा की तारीख/Pronouncement On: 25/09/2024

disallowance made in the intimation under section 143(1) and therefore, the assessee did not get sufficient opportunity to ventilate their grievance on this aspect. 6. Learned AR placed reliance on the decision of the Hon'ble Apex Court in the case of Commissioner of Income Tax Vs. Gujarat Electricity Board (2003) 260

DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD vs. KMC CONSTRUCTIONS LIMITED, HYDERABAD, HYDERABAD

In the result, the appeal of Revenue is dismissed, and the appeal of assessee is partly allowed

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

section 40A(3) could not be invoked. Apart from this, the order of the learned Assessing Officer does not spell out as to the distance of the sites from the urban areas of Allahabad, Kurnool etc., but going by the name of the site, learned Assessing Officer concluded that the payments in cash at such places is not justified

KMC CONTRUCTIONS LIMITED, HYDERABAD,HYDERABAD vs. ADDL. CIT, RANGE-2, HYDERABAD, HYDERABAD

In the result, the appeal of Revenue is dismissed, and the appeal of assessee is partly allowed

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

section 40A(3) could not be invoked. Apart from this, the order of the learned Assessing Officer does not spell out as to the distance of the sites from the urban areas of Allahabad, Kurnool etc., but going by the name of the site, learned Assessing Officer concluded that the payments in cash at such places is not justified

CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

In the result, all the appeals of the assessee are allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

disallowance of the claim under Section 80IA after the search proceedings carried out on the searched person 12 SABIR, SEW & PRASAD JV when no incriminating material was found disclosing the escapement of income as required u/s 153C of the Act. 8. Per contra, Ld.DR submitted that in the present case, the search was carried out in the premises

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

disallowed the corresponding discounted rate of interest element pertaining to the said loan, which, however, as per the directions of the DRP had already been restricted up to the date of repayment of the said loan. 45 ITA TP 466/Hyd/2022 and 1301/Hyd/2024 Dodla Dairy Limited. 45. The Ld. CIT-DR, on the issue of quantification of claim of deduction

INCOME TAX OFFICER, WARD-8(1), HYDERABAD vs. MVVS ALIENS (JV), HYDERABAD

Appeal is allowed for statistical purposes in foregoing terms

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

Section 40(a)(ia) disallowance of Rs.7,12,81,805/- made in the course of assessment on account of assessee’s failure in not deducting TDS qua its payments made to the JV partners, :- 2 -: M/s.Alliens Developers Pvt. Ltd. The CIT(A)’s detailed discussion deleting the impugned disallowance reads as under: “3. Brief facts of the case are that

DCIT., CIRCLE-2(1), HYDRABAD vs. KALPTARU INVESTMENTS PRIVATE LIMITED, HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1077/Hyd/2025

section 143(3) was passed on 24.02.2016 determining income at Rs.91,260/- on account of disallowance under section 14A of the Income

SRI KSSV FINVEST PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. ITO, WARD-3(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 Sri Kssv Finvest Pvt. Ltd., Vs. Income-Tax Officer, Hyderabad. Ward – 3(3), Hyderabad. Pan – Aaack9655Q (Appellant) (Respondent)

section 14A and relying on the decision of Kerala High Court in the case of CIT Vs. State Bank of Travancore, 203 Taxmann 639 and in the case of Bellwether Microfinance Fund in ITA No. 1743/Hyd/2013, dated 22/06/14, computed the disallowance u/s 14A rwr 8D at an amount of Rs. 6,48,076/-, which

INFOR (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

Accordingly treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं / Ita-Tp No. 193/Hyd/2023 (निर्धारण वर्ष / Assessment Year: 2018-19) Infor (India) Private Limited, Vs. The Deputy Commissioner Hyderabad Of Income Tax, [Pan No. Aaacb6197Q] Circle-2(1), Hyderabad अपीलार्थीर्थी / Appellant प्रत्‍यर्थी / Respondent

section 260 and 144B of the Act. Hence the assessee is in appeal before us challenging the final assessment orders pursuant to the directions made by the Learned DRP. 5. Grounds No. 1 ,2 and 16 to 18 of this appeal are general in nature. Grounds No. 3 to 8 relate to the Transfer Pricing adjustment on account of provision

DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD vs. HYDERABAD MENZIES AIR CARGO PRIVATE LIMITED , HYDERABAD , HYDERABAD

In the result, appeals of the assessee are allowed"

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

260/- u/s 115JB of the Act. 2.1 The AO completed the assessment u/s 143(3) of the Act on 29/02/2016 determining the assessed income at Rs. 32,77,45,976/- as against the returned income of Rs. 3,12,09,190/- under normal provisions, disallowing the assessee’s claim of deduction of Rs. 29,65,36,784/- u/s 80IA

DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD vs. HYDERABAD MENZIES AIR CARGO PRIVATE LIMITED , , HYDERABAD

In the result, appeals of the assessee are allowed"

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

260/- u/s 115JB of the Act. 2.1 The AO completed the assessment u/s 143(3) of the Act on 29/02/2016 determining the assessed income at Rs. 32,77,45,976/- as against the returned income of Rs. 3,12,09,190/- under normal provisions, disallowing the assessee’s claim of deduction of Rs. 29,65,36,784/- u/s 80IA

SABIR, SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ष / Assessment Years: 2006-07, 2007-08 & 2008-09)

disallowance of the claim under Section 80IA after the search proceedings carried out on the searched person when no incriminating material was found disclosing the escapement of income as required u/s 153C of the Act. 8. Per contra, Ld.DR submitted that in the present case, the search was carried out in the premises of the searched person

SABIR , SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

disallowance of the claim under Section 80IA after the search proceedings carried out on the searched person when no incriminating material was found disclosing the escapement of income as required u/s 153C of the Act. 8. Per contra, Ld.DR submitted that in the present case, the search was carried out in the premises of the searched person