MYLAN LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER INCOME TAX , CIRCLE-5 (1) , HYDERABAD

In the result, the ground no

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

section 263 by the Ld. PCIT, ground no. 4 related to disallowance of termination charges of Rs.340.45 crores paid to Pfizer

RK INFRA & ENGINEERING INDIA PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-3, HYDERABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2015-16 R.K. Infra & Engineering India Vs. Income Tax Officer, Private Limited, Ward – 3, Hyderabad. Hyderabad. Pan : Aadcr9570Q (Appellant) (Respondent) Assessee By: Shri Pawan Kumar Chakrapani Revenue By: Shri Jeevan Lal Lavidiya Date Of Hearing: 21.11.2022 Date Of Pronouncement: 22.11.2022

section 263 of the Act, passed by the Honorable POT needs to be deleted on this count alone. 11 9.7 It is further submitted that the Appellant has not borrowed any loans from any bank or financial institutions, and no amount which is borrowed on which the Appellant has paid interest were transferred to attract disallowance

M/S N.A.M. EXPRESSWAY LIMITED,DELHI vs. ACIT., CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.580/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19) N.A.M.Expressway Ltd. Vs. Acit, Circle-5(1) Delhi Hyderabad [Pan : Aadcn3131D] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Salil Kapoor, Ms Ananya Kapoor & Shri Tarun Chanana, Ar (Through Virtual Mode) रधजस् व द्वधरध/Revenue By: Shri Shiva Sewak, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 30/10/2024 घोर्णध की तधरीख/Date Of 28/01/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.03.2019 Of The Learned Principal Commissioner Of Income Tax [Ld.Pcit], Hyderabad-4 Pertaining To A.Y.2018-19 On The Following Grounds :

section 263 of Income-of the Income tax Act, 1961 (“the Act”), 1961 (“the Act”) by Principal Commissioner of Income Tax [Hon'ble PCIT] is bad in law and liable to be quashed. 2 M/s N.A.M.Expressway Limited 2. That, on the facts and circumstances of the case and in law, Hon'ble PCIT has erred in initiating revisionary proceedings

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

PENNAR INDUSTRIES LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1),, HYDERABAD

In the result, the appeal filed by the assessee company is partly allowed/partly allowed for statistical purposes

Bench: Us:

Section 263 of the Act on certain issues, viz. (i) the omission to disallow the deduction of reversal of provision

BSCPL AURANG TOLLWAY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is dismissed

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay, wherein it was submitted that the appeal for the relevant assessment year was required to be filed within 60 days from the date of receipt of the order passed under Section 263 of the Income-tax Act, 1961. However, the

Section 263 of the Income Tax Act, 1961 has been issued and called upon the assessee to file its objections, if any, for proposed revision of 5 BSCPL Aurang Tollway Limited assessment order. The Ld. PCIT, Hyderabad-1, observed that, the assessee company was incorporated under Companies Act, 1956, as a Special Purpose Vehicle (SPV) and is engaged

RAJASEKHAR NAIDU GALLA,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATHI

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

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

Section 263 of the Income-tax Act, 1961, dated 14.03.2025 was issued, calling upon the assessee to explain as to why the assessment shall not be revised. In the said show-cause notice, the learned PCIT was of the opinion that, the assessment order passed by the A.O. is erroneous insofar as it is prejudicial to the interest

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

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

263 r.w.s. 144B of the Income-tax Act, 1961, on 24.09.2021 and determined the total income at Rs. 28,46,91,790/- by making additions of Rs. 8,77,278/- towards disallowance of interest on TDS and further disallowance of EPF & ESI under Section

AMARA RAJA POWER SYSTEMS LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

disallowances arising out of the payments made\nto the contractors, therefore, the Pr. CIT had wrongly observed that\nthe A.O. had passed the assessment order without making\ninquiries or verification that should have been made. The Ld. A.R.\nfurther submitted that the Pr. CIT had, based on his incorrect\nobservations, triggered the “Explanation 2(a)” to Section 263

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

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

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

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

NSL RENEWABLE POWER PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-5(1), HYDERABAD

In the result, appeal of the assessee is allowed

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

disallowance u/s. 37(1) of the Act towards land lease compensation to Karnataka Forest Department. 4. Subsequently, Ld. PCIT on a perusal of the assessment record felt that the assessment order is erroneous and prejudicial to the interest of justice and, therefore, issued a notice 10/02/2021 under Section 263

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

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

section 263 did not make any disallowance u/s 80IA for these assessment years. The above said fact became relevant as the assessee