ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

2. The submission of Id. Principal CIT(DR) is that ITAT in the case of Delhi Special Bench in the case of Cheminvest Ltd. (supra) has specifically held that even if there is no exempt income, the provisions of section 14A are applicable in view of the decision of Hon'ble Supreme Court in the case of Rajednra Prasad Moody

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

2. The submission of Id. Principal CIT(DR) is that ITAT in the case of Delhi\nSpecial Bench in the case of Cheminvest Ltd. (supra) has specifically held that\neven if there is no exempt income, the provisions of Section 14A are applicable\nin view of the decision of Hon'ble Supreme Court in the case of Rajednra\nPrasad Moody

KRISHNA KISHORE REDDY MANYAM ,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(4) , HYDERABAD

In the result, the appeal filed by the assessee is partly allowed\nfor statistical purposes in terms of our aforesaid observations

disallowed the same.\n5. Ostensibly, the assessee during the course of the assessment\nproceedings came up with a new claim, wherein based on a revised\nstatement of computation of income that was filed with the A.O.\non 29.08.2010, it was claimed by him that as the agricultural land\nsituated at Village: Manchirevula was not a “capital asset” within\nthe meaning

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

disallowed U/s.40A(3) and is added to the total income of the assessee. 14.1 On appeal, the ld.CIT(A) had decided the issue at pages 70 to 74 of the order wherein he observed as under : “The claim of the appellant that the payments have been made by the M/s. DLF group is false and completely unsubstantiated and no confirmation

CO-OPERATIVE ELECTRIC SUPPLY SOCIETY LTD.,KARIMNAGAR vs. DCIT., CIRCLE-1, KARIMNAGAR

Bench: Us:

2,70,23,274/-. The return of income filed by the assessee Co-operative Society was initially processed as such under Section 143(1) of the Act. Thereafter, the A.O., taking cognizance of the fact that the assessee Co-operative Society had failed to deposit the employees’ share of contributions towards various welfare funds within the prescribed time period, which

CO-OPERATIVE ELECTRIC SUPPLY SOCIETY LTD.,,SIRICILLA vs. DCIT., CIRCLE-1, KARIMNAGAR

Bench: Us:

2,70,23,274/-. The return of income filed by the assessee Co-operative Society was initially processed as such under Section 143(1) of the Act. Thereafter, the A.O., taking cognizance of the fact that the assessee Co-operative Society had failed to deposit the employees’ share of contributions towards various welfare funds within the prescribed time period, which

SEVA BHARATHI,HYDERABAD vs. ITO., EXEMPTION WARD 1(4), HYDERABAD

In the result, ITA.No.1307/Hyd

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.365 & 1307/Hyd/2025 िनधा"रण वष"/Assessment Year 2022-2023 Seva Bharathi, The Commissioner Of Hyderabad – 500 018. Income Tax Vs. Telangana. (Exemptions), Ward-1(4), Pan Aayts5233K Hyderabad – 500 004. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sri Harsha राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 08.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao:

274 (Supreme Court), held that section 10A of the Act is a "deduction provision" and not an "exemption provision". Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as "Exemption" or Deduction" provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute

SEVA BHARATHI,HYDERABAD vs. CIT., EXEMPTION WARD 1(4), HYDERABAD

In the result, ITA.No.1307/Hyd

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.365 & 1307/Hyd/2025 िनधा"रण वष"/Assessment Year 2022-2023 Seva Bharathi, The Commissioner Of Hyderabad – 500 018. Income Tax Vs. Telangana. (Exemptions), Ward-1(4), Pan Aayts5233K Hyderabad – 500 004. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sri Harsha राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 08.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao:

274 (Supreme Court), held that section 10A of the Act is a "deduction provision" and not an "exemption provision". Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as "Exemption" or Deduction" provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute

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

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

disallowed on a technical reason of delay in\nfiling of the Audit Report in Form No. 10B, which is due to\na reasonable cause and the same is beyond the control of\nthe appellant.\n4.\nThe Ld. CIT(A) has erred in observing that the appellant\nhas not given any reasonable cause for delay in filing the\nappeal by over

D S R INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

D S R INFRASTRUCTUREPRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE- 1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

DCIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

disallowance of 20% of the unexplained investment and therefore, we remand back the matter to the file of Assessing Officer with a direction to the assessee to file necessary explanation with respect to the amount of Rs.11,39,92,517/- and explain as to why this amount should not be added to the account of the assessee and in case

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

disallowed on a technical reason of delay in\nfiling of the Audit Report in Form No. 10B, which is due to\na reasonable cause and the same is beyond the control of\nthe appellant.\n4.\nThe Ld. CIT(A) has erred in observing that the appellant\nhas not given any reasonable cause for delay in filing the\nappeal by over