CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

In the result, all the appeals of the assessee are allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

3) r.w.s. 153C for AY 2006-07 was completed on 31.12.2009, disallowing the assessee's claim u/s 80IA. The CIT(A) upheld the disallowance on 30.03.2010. On further appeal, the ITAT, vide order dated 19.08.2013 in ITA No. 963/Hyd/2010, remitted the issue to the AO for fresh examination in light of the decision in M/s Ramky Infrastructure Ltd. Accordingly, notice

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MEGHA ENGINEERING AND INFRASTRUCTURES LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is partly allowed

Bench: Shri Manjunatha G. Hon’Ble & Shri Prakash Chand Yadav, Hon’Bleassessment Year – 2020-21 The Assistant Commissioner Of Vs. M/S.Megha Engineering & Infrastructure Ltd. Income Tax, Hyderabad. Central Circle – 2(1), Hyderabad. Pan : Aaecm7627A

3. The ld. CIT(A) erred in not appreciating the fact that the assessee herein is not a developer but merely a contractor in respect of the projects awarded to the JV / Consortia. 4. The ld.CIT(A) erred in ignoring that the facts of the case are not in conformity with clarificatory amendment to Section 80IA of the Act [Explanation

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, MADHAPUR

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowing the deduction under Section 80-IA of the Act. For the above-mentioned purposes, ld.AR has drawn our attention to the Explanation below Sub-section (4) of 80IA of the Act, which was captured by the Assessing Officer at page 10 of his assessment order, which reads as under : “…..The assessee’s claim is that its case falls under

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, HYDERABAD

disallowing the deduction under Section 80-IA of the Act. For the above-mentioned purposes, ld.AR has drawn our attention to the Explanation below Sub-section (4) of 80IA of the Act, which was captured by the Assessing Officer at page 10 of his assessment order, which reads as under : “.....The assessee's claim is that its case falls under

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)

3) of the Act. 4. Thereafter, the A.O. has passed the draft assessment order under Section 144C(1) of the Income-tax Act, 1961 on 30.03.2024, determining the total income at Rs. 1,74,92,25,390/- by making addition towards TP adjustment suggested by the Ld. TPO, addition towards disallowance

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

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

disallowance of donations under Section 80G towards CSR expenditure. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Ms. Tanmayee Rajkumar, Advocate, referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.06.2024, submitted that, the assessment

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. CHINTHAKUNTA RAMESH SRIDEVI, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD, HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

GVPR ENGINEERS LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1(3) , HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD, HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CC-1(3), HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE1(3), HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

4)(iv)(b). Since he disallowed the claim of deduction under this section for Rs.14,59,30,268 in the order u/s 143(3

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

4 ITA 1862/Hyd/2017 Brightcom Group Limited 13. The Ld. AO erred in not considering the fact that the time2. The Ld. AO erred in not considering the fact that the time limit prescribed u/s 153 would prevail over and above the time limit prescribed u/s 144C. Therefore, the assessment order u/s 144C(1) is void

SUSHEE INFRA & MINING LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

sections 32, 40(a)(ia), 40A(3), 43B etc. of the Act and other specific disallowances, related to the business activity against which the Chapter Vl-A deduction has been claimed, result in enhancement of the profits of the eligible business, and that deduction under Chapter, VI-A is admissible on the profits so enhanced by the disallowance. 4

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

sections 32, 40(a)(ia), 40A(3), 43B etc. of the Act and other specific disallowances, related to the business activity against which the Chapter Vl-A deduction has been claimed, result in enhancement of the profits of the eligible business, and that deduction under Chapter, VI-A is admissible on the profits so enhanced by the disallowance. 4