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

In the result, appeal of the Revenue is dismissed

disallowing the same considering the provisions of\nSec.40A(3) of Income Tax Act. This admitted additional\nincome of Rs.60,44,76,909/- over and above the regular\nincome of M/s IIPPL for FY 2017-18. Τo this extent we are\nsubmitting herewith provisional balance sheet and\ncomputation of Income.\"\n4.3. Subsequently, the assessee company admitted this\nundisclosed income

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

disallowing the said amount in the return of income. Provisions of sub-section 6 of section 270A carves out an exception

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 Rs. 82,63,156 for under-reporting of income w.r.t the disallowance of HEC of Rs. 4,81,53,591/-. 6

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

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

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

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

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

disallowance of impairment loss in respect of valuation of closing inventory and, for the reasons stated in their order, in the preceding paragraph nos. 9 to 11, has deleted the addition made by the A.O. towards closing inventory of raw materials. Once the addition made by the A.O., on which penalty was levied by the A.O. under Section 270A

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)

disallowance of impairment loss in respect of valuation of closing inventory and, for the reasons stated in their order, in the preceding paragraph nos. 9 to 11, has deleted the addition made by the A.O. towards closing inventory of raw materials. Once the addition made by the A.O., on which penalty was levied by the A.O. under Section 270A

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

6. That the facts and circumstances of the case, DRP is not justified in confirming the ALP of fly ash at Rs. 65.76/- per ton, determined without considering the freight component s part of landed cost of fly-ash, and making an adjustment of Rs. 60,90,830/-. 7. That in the facts and circumstances of the case

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

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

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

M G B MOTOR AND AUTO AGENCIES PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

In the result, appeal of the assessee is allowed

Bench: Shri Manjunatha .G & Shri K.Narasimha Chary

disallowance of commission expenses U/s. 40(a)(ia) of the Act, on ad-hoc and es"ma"on basis. 3. The learned AO also ini"ated penalty proceedings U/s 270A read with sec"on 274 of the Act by issuing no"ce dated 20/04/2021. In its reply dated 28/04/2021, the assessee submi"ed that the penalty U/s. 270A for under

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

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)

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

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)

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