BHEL LCC SOCIETY LTD,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.732/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Bhel Lcc Society Ltd Vs. Dy.Cit Hyderabad Circle 8(1) Pan:Aaatb6430D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sri Sai Keerthana राज" व "ारा/Revenue By:: Shri Dr. Sachin Kumar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 01/09/2025 घोषणा की तारीख/Pronouncement: 04/09/2025 आदेश/Order Per Vijay Pal Raothis Appeal By The Assessee Is Directed Against The Order Dated 27/02/2025 Of The Learned Cit (A)-Nfac Delhi, Arising From The Penalty Order Passed U/S 270A Of The I.T. Act For The A.Y.2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

section 270A leads to the inference that if the income is assessed greater than the income reported in the return of income or determined in the return processed u/s 143(1)(a) and the addition in the total income of the assessee is due to the reason of misrepresenting or suppressing of facts, failure to record the investment

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

10 and 11 of Appendix-1, the term “employer” has been used in the context of the assessee. Page 12 of 20 ITA No 670 of 2023 Nippon Koei Co Ltd g. He shall be paid monthly fees of US$ 35,000 and shall be allowed 15 days paid leave per year (Appendix-2). 12.2 These attributes fundamentally align with

ACIT-CENTRAL CIRCLE-2(4), HYDERABAD vs. INCREDIBLE INDIA PROJECTS PRIVATE LIMITED, SECUNDERABAD

In the result, appeal of the Revenue is dismissed

10,35,484/-\nwere shown as advance to landlords for the year ending on\n31.03.2016, advance to landlords for the year ending on\n31.03.2017 and \"Pre-Paid development expenses\" for the\nyear ending on 31.03.2017 respectively. However, these are\nactually cash payments made to Mis Aurora Educational\nSociety, which were not allowable as expenses. Please offer\nyour comments.\nAns

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

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

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.1295/Hyd/2025 (िनधा"रण वष"/Assessment Year:2020-21) M/S. Granules India Limited, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan : Aaacg7369K Circle 2(1), Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025

270A of the Act w.r.t the disallowance of HEC of Rs. 4,81,53,591/-. The CIT(A) observed that the assessee company contended that it had claimed “education cess” as a deduction relying on the judgment of the Hon’ble High Court of Bombay in the case of Sesa Goa Ltd. Vs. Jt. CIT (2020) 423 ITR 426 (Bombay

SGD PHARMA INDIA PRIVATE LIMITED, ,MAHABUBNAGAR vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee in ITA\nNo

270A of the Act\nThe Appellant craves leave to add to, alter, omit or substitute any or all of the above grounds of\nappeal, at any time before or at the time of the appeal.\nSGD Pharma India Private Limited\nName: Sardar Akshay Singh\nDesignation: Managing Director\n3. The assessee has raised the following additional\ngrounds

BABA AKHILA SAI JYOTHI INDUSTRIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.987/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) Baba Akhila Sai Jyothi Vs. Dy. Cit Industries Private Ltd Circle 1 ( 1 ) Hyderabad Hyderabad Pan:Aadcb3413C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Shri Srinath Sadanala, Dr सुनवाई की तारीख/Date Of Hearing: 02/12/2024 घोषणा की तारीख/Pronouncement: 05/12/2024 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated, 6/8/2024 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2018-19. 2. The Assessee Has Raised The Following Grounds: “1. On The Facts & In The Circumstances Of The Case, The Order Of The Learned Cit (A) Is Erroneous Both On Facts & In Law. 2. The Learned Cit (A) Erred In Sustaining The Penalty Of Rs.5,80,424/- Levied By The Assessing Officer U/S 270A Of The I.T. Act, 1961. Page 1 Of 8

disallowance; (d)the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction

RAGHU RAMA RENEWABLE ENERGY LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

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)

10. There is no dispute with regard to the fact that, the assessee has stopped generation of power because the plant was stopped in May, 2015 due to feasibility reasons and the raw material held by the assessee in the process of generation of power was still lying in the power plant since 2015. The assessee has valued the closing

RAGHU RAMA RENEWABLE ENERGY LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

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

10. There is no dispute with regard to the fact that, the assessee has stopped generation of power because the plant was stopped in May, 2015 due to feasibility reasons and the raw material held by the assessee in the process of generation of power was still lying in the power plant since 2015. The assessee has valued the closing

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 of business support service expense of INR 75,91,57,538 for non-deduction of Tax Deducted at Source ('TDS') under section 40(a)(i) of the Act. 2.2 Additionally, on the facts and circumstances of the case, and contrary to the law, the Ld. AO erred. and the Hon'ble DRP further erred in: 3 ADP Private Limited

EXCELRA KNOWLEDGE SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.545/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Excelra Knowledge Vs. Dy.Cit Solutions Private Limited Circle 8(1) Hyderabad Hyderabad Pan:Aafcg5715Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H Srinivasulu राज" व "ारा/Revenue By:: Shri Ranjan Agrawala, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Pronouncement: 26/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Excelra Knowledge Solutions Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 22.01.2025 For The A.Y 2018-19. Page 1 Of 8

disallowance; (d)the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

270A for the said previous\nyear.\n[Provided also that the provisions of this clause shall not apply on\nor after the 1st day of April, 2025.]\nExplanation. For the purposes of this clause,-\n(a) the fair market value of the shares shall be the value-\n(i) as may be determined in accordance with such method as\nmay

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

270A for the said previous\nyear.\n[Provided also that the provisions of this clause shall not apply on\nor after the 1st day of April, 2025.]\nExplanation. For the purposes of this clause,-\n(a) the fair market value of the shares shall be the value-\n(i) as may be determined in accordance with such method as\nmay

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

270A for the said previous\nyear.\n[Provided also that the provisions of this clause shall not apply on\nor after the 1st day of April, 2025.]\nExplanation. For the purposes of this clause,-\n(a) the fair market value of the shares shall be the value-\n(i) as may be determined in accordance with such method as\nmay

VEERA REDDY POSHAM,NALGONDA vs. ACIT, CENTRAL CIRCLE-1(1), HYDERABAD

In the result, ITA.No.1830/Hyd

sections": [ "143(3)", "147", "148", "250(6)", "80C", "10(13A)", "234A", "234B", "234C", "234F", "270A", "132", "142(1)", "69", "115BBE", "292C" ], "issues": "Whether the CIT(A) erred in upholding additions on account of disallowance

MAGNAQUEST TECHNOLOGIES LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, ITA.No.736/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 270A under which the penalty proceedings are initiated in the appellant case and hence the penalty order passed by AO u/s 270A is liable to be quashed. 3. That on the facts and circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi has erred in not appreciating

MAGNAQUEST TECHNOLOGIES LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, ITA.No.736/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 270A under which the penalty proceedings are initiated in the appellant case and hence the penalty order passed by AO u/s 270A is liable to be quashed. 3. That on the facts and circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi has erred in not appreciating

VEERA REDDY POSHAM,NALGONDA vs. ACIT, CENTRAL CIRCLE1(1), HYDERABAD

In the result, ITA.No.1830/Hyd

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.Nos.1829 & 1830/Hyd/2025 Assessment Years 2020-2021 & 2022-2023 Veera Reddy Posham, The Acit, Nalgonda – 508 246 Central Circle-1(1), Vs. Telangana. Hyderabad. Telangana. Pan Aijpp0376P (Applicant) (Respondent) -None- िनधा"रती "ारा/Assessee By : राज" व "ारा/Revenue By : Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 09.03.2026 घोषणा की तारीख/Pronouncement: 13.03.2026 आदेश/Order Per Vijay Pal Rao:

section 10(13A).  The disallowance was made merely for want of documents at assessment stage without providing opportunity to cure the procedural deficiency during appellate stage; the same deserves to be deleted. F. Levy of Interest & Penalty  The levy of interest u/ss 234A, 234B, 234C and fee u/s 234F is consequential and without proper computation.  The initiation of penalty proceedings

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowing expenditure relatable to exempt income by invoking the provisions of section 14A r.w.s.8D of Income Tax Rules, 1962, even though the assessee has not earned any dividend income, which is exempt u/s 10(34) of the Act. The Ld.CIT(A), after considering the relevant facts has rightly deleted the additions made by the A.O. Thus, we are inclined