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

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

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

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

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

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

SYED AHMED ZEESHANUDDIN,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2 , HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

2. The Ld.A.O. grossly erred in invoking the provisions of sec.153C of the I.T.Act without there being any incriminating material found belonging to the appellant during the course of search in the premises of third party. 3. The Ld.A.O ought to have appreciated the fact that the issuance of notice u/s 153C has to be done before the completion

ASRA AHMED ,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

2. The Ld.A.O. grossly erred in invoking the provisions of sec.153C of the I.T.Act without there being any incriminating material found belonging to the appellant during the course of search in the premises of third party. 3. The Ld.A.O ought to have appreciated the fact that the issuance of notice u/s 153C has to be done before the completion

KOLLURU VENKATESH,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-11(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2017-18 Kolluru Venkatesh, Vs. The Assistant Commissioner Of Income Tax, Secunderabad. Ward – 11(3), Hyderabad. Pan : Cdopk7445J (Appellant) (Respondent) Assessee By: Ms. S. Sandhya, Advocate Revenue By: Shri Sadanala Srinath, Sr.Ar. Date Of Hearing: 05.02.2025 11.02.2025 Date Of Pronouncement:

disallowance of the entire deduction. Penalty proceedings under section 270A for under-reporting of income and section 272A(1)(d) for failure to comply with notices under section 4 142(1) were initiated separately. Finally, Assessing Officer completed the assessment u/s 143(3) of the Act on 30.12.2019, determining the total income of the assessee at Rs.3

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

2. The brief facts of the case are that the assessee company filed its return of income for the A.Y.2016-17 on 17.10.2016, admitting loss at Rs.1,19,39,478/- under normal provisions of Income Tax Act, 1961 (“the Act”) and book profit of Rs.Nil. The case was selected for scrutiny and during the course of assessment proceedings, the A.O. noticed

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)

2. The brief facts of the case are that the assessee company filed its return of income for the A.Y.2016-17 on 17.10.2016, admitting loss at Rs.1,19,39,478/- under normal provisions of Income Tax Act, 1961 (“the Act”) and book profit of Rs.Nil. The case was selected for scrutiny and during the course of assessment proceedings, the A.O. noticed

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

2. The brief facts of the case are that the assessee company filed its return of income for the A.Y.2016-17 on 17.10.2016, admitting loss at Rs.1,19,39,478/- under normal provisions of Income Tax Act, 1961 (“the Act”) and book profit of Rs.Nil. The case was selected for scrutiny and during the course of assessment proceedings, the A.O. noticed