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

In the result, appeal of the Revenue is dismissed

disallowed the same, as those were found to have been\nincurred in a mode other than that prescribed in Section 40A(3) of\nthe Act, i.e. a deeming provision, therefore, in absence of having\nrecorded a false entry in the books of accounts it could not have\nbeen subjected to penalty under Section 270A(9

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

9. Ostensibly, the CIT(A) had confirmed the penalty imposed by the AO under Section 270A of the Act w.r.t the disallowance

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.:

9 of 20 ITA No 670 of 2023 Nippon Koei Co Ltd Page 10 of 20 ITA No 670 of 2023 Nippon Koei Co Ltd Page 11 of 20 ITA No 670 of 2023 Nippon Koei Co Ltd 12.1 On careful examination of the relevant clauses of the agreement, we find the following features: a. Mr. Tony shall report

SOMA SEKHAR POLAVARAPU,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

disallowance made by the A.O. during assessment proceedings cannot be a reason for levy of penalty u/s.270A of the Act. The Ld. CIT(A) further failed to appreciate that the penalty proceedings are independent of quantum proceedings. 6. Any other ground that may be urged at the time of hearing.” 3. Brief facts of the case are that an addition

SHR INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

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

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

9)(c) is not sustainable as the A.O. made a summary disallowance of expenses @ 50% and is not covered under any of the sub-clauses of Section 270A

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

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

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

9) of section 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

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

9) of section 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

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

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

9) of section 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

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

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

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

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

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

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

In the result, appeals filed by the Revenue for the assessment years 2017-18 and 2018-19 are allowed for statistical purpose

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.604 & 605/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Acit Vs. Incredible India Projects Central Circle-2(4) Private Limited Hyderabad Secunderabad [Pan : Aabci9355A] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Sandeep Goel, Ar रधजस् व द्वधरध/Revenue By:: Shri B.Bala Krishna, Cit, Dr सुिवधई की तधरीख/Date Of 19/09/2024 Hearing: घोर्णध की तधरीख/Pronouncement: 14/11/2024 आदेश / Order Per. Manjunatha G., A.M: These Two Appeals Filed By The Revenue Are Directed Against The Separate, But Identical Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Both Dated 30/08/2022, Pertaining To A.Y.2017-18 & 2018-19. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

9)(d) of the Act as the assessee admitted to disallow cash payments of Rs.65,28,28,100/- made to M/s Aurora Educational Society vide his statement recorded during search proceedings. 3. The Ld.CIT(A) ought to have appreciated the fact that in order to escape from the penal provisions of dealing in cash the assessee disguised and camouflaged

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

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