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

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

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

Bench: the due date provided for filing return of income u/s 139(1) of the Act, which attracts the provisions section 43B, however, the said amount 3

2) of the Act and in case, penalty proceedings have been initiated u/s 270A(9) of the Act, then the question of filing application by an assessee does not arise and consequently, the AO need not pass an order under sub section (4) of section 270AA of the Act. In the present case, since the AO has initiated penalty

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

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

In the result, appeal of the Revenue is dismissed

2), Hyderabad, ITA No.642/Hyd/2023\ndated 29.02.2024. On careful perusal of both the aforesaid\norders, we find that the Tribunal had in the said respective cases,\nobserved that as the AO had in his penalty order not spelled out\nthe specific instance, i.e., clause (a) to (f) of sub section (9) of\nSection 270(A) of the Act for which penalty

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

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

270A of the Act, in respect of additions made by the A.O. towards disallowance of interest expenses under Section 36(1)(iii) of Rs. 14,16,045/- and disallowance of claim of impairment loss in respect of valuation of closing stock of inventory of raw materials of Rs. 2

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)

270A of the Act, in respect of additions made by the A.O. towards disallowance of interest expenses under Section 36(1)(iii) of Rs. 14,16,045/- and disallowance of claim of impairment loss in respect of valuation of closing stock of inventory of raw materials of Rs. 2

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.:

disallowance of Rs.13,76,205/- made under section 40(a) of the Act. Accordingly, Ground No.4 of the assessee is allowed for statistical purposes. 19. Ground No.5 raised by the assessee is in respect of initiation of penalty proceedings by the Ld. AO under section 270A of the Act. The initiation of penalty proceedings is only a consequential and preliminary

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

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

Section 270A of the Income-tax Act, 1961, dated 27.09.2022, for the Assessment Year 2020-21. The assessee company has assailed the impugned order of the CIT(Appeals) on the following grounds of appeal before us: ITA No.1295/Hyd/2025 2 “1. On the facts and in the circumstances of the case, the learned Commissioner of Income-tax (Appeals), NFAC, Delhi

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

Bench: Us:

disallowing interest expenditure of INR 208,333 under section 37 of the Act disregarding the fact that the differential interest amount (market value of interest income vs interest charged from employee) was already taxed as perquisite in the hands of the Managing Director. 14. On the facts and in the circumstances of the case and in law, the LA. AO/LA

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

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

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

disallowing expenses amounting to INR 20,32,596\nunder Section 43B of the Act despite the specific direction of the Ld. Panel to allow the same.\n7.\nOn the facts and in the circumstances of the case and in law, the Ld. AO erred in initiating the\npenalty proceedings under section 270A of the Act\nThe Appellant craves leave

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.

270A. Furthermore, the company had claimed Rs. 8,61,457 as income tax for the assessment year 2018-19 under other expenses, which was required to be disallowed under section 37(1) as expenditure of a personal nature. Hence, notices were issued to the assessee on 29.08.2022, and 31.10.2023, under section 142(1) to explain the claim, but no response

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

2,07,80,414 while computing the assessed income without giving effect to the Hon'ble DRP directions in this regard. b) making disallowance of INR 34,35,859 towards delay in deposit of employees contribution to provident fund under section 36(1)(va) of the Act, without appreciating the fact that the same were deposited on or before

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

section 92E of the Act. Thereafter, the case was referred to the Transfer Pricing Officer (“TPO”) on 25/10/2019 for determining the Arm’s Length Price (“ALP”) after obtaining the necessary approvals from the Ld. Pr. CIT-3, Hyderabad, dated 18/10/2019. Accordingly, notice U/s. 92CA(2) of the Act was issued on 26/11/2019 and subsequent notice / questionnaire was also issued

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

270A. Penalty for under-reporting and misreporting of income. (1)…… 2……. 3……... 4……… 5…….. .(6)The under-reported income, for the purposes of this section, shall not include the following, namely:— (a)the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner or the Principal Commissioner

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

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 ITA No 987 of 2024 Baba Akhila Sai Jyothi Industries P Ltd 3. The learned CIT (A) failed to appreciate that the appellant has voluntarily offered for the disallowance

ASCENTECH ENGINEERING SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

disallowance of the entire premium of Rs.45 lakhs while passing the impugned order.\nThe learned Authorised Representative of the Assessee has submitted that it is well settled law as laid down by the Hon'ble High Courts as well as various Benches of this Tribunal the Assessing Officer has no jurisdiction to substitute the method of valuation as selected