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

58 ITR(T) 313, the Ld. AR submitted that only those investments which yielded exempt income during the relevant year could be considered for the purpose of computing disallowance under Rule 8D of the Rules. Accordingly, it was submitted that even if any disallowance was to be made under section

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

58 ITR(T) 313, the\nLd. AR submitted that only those investments which yielded exempt income\nduring the relevant year could be considered for the purpose of computing\ndisallowance under Rule 8D of the Rules. Accordingly, it was submitted that\neven if any disallowance was to be made under Section

PRASAD FILM LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-6(1), HYDERABAD

In the result appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

disallowance made by the Assessing Officer under Section 14A read with rule 8D is bad in law, as the Learned Assessing Officer failed to record his dissatisfaction with regard to the correctness of the appellant's claim, as required under Section 14A(2) of the Income-tax Act, 1961." 3 ITA.No.113/Hyd./2025 4. After hearing both the sides

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

disallowance of deduction under section 80-IA\nin respect of the sale of scrap and interest receipts is not sustainable.\nAs a result, ground no 5 is allowed.\n7. In result, the appeal is allowed.\"\n36. The revenue aggrieved with the CIT(A) order has carried the\nmatter in appeal before us.\n37.\nShri. Sourabh Soparkar, Senior Advocate

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.:

section 201(1A) of the Act of Rs.2,10,265/-, Disallowance of lead role expenditure of Rs.19,58,509/-, Disallowance

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, 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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DCIT, 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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, 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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, 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

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

VK WAREHOUSING ENTERPRISES,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

58,38,297/-; (ii) disallowance of depreciation: Rs. 3,11,24,473/-; (iii) disallowance under Section 40(a)(ia) of the Act: Rs. 32,89,736/-; (iv) disallowance

ACIT., CIRCLE-5(1), HYDERABAD vs. MYLAN LABORATORIES LIMITED, HYDERABAD

In the result. appeal of the Assessee is partly allowed for statistical purposes and appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 35(2AB) of the Act and disallowance u/se.14A of the Act. 8. Aggrieved by the order of the learned CIT(A), the appellant company and the Revenue are now in appeal before the Tribunal. 9. The first issue that came-up for consideration from grounds of appeal of the appellant company is, TP adjustment in respect of sale

ACIT., CIRCLE-6(1), HYDERABAD vs. VK WAREHOUSING ENTERPRISES, HYDERABAD

In the result, both the appeals filed by the assessee firm and\nthe revenue are partly allowed for statistical purposes, in terms of\nour observations recorded hereinabove

Section 69C\nof the Act: Rs. 34,58,38,297/-; (ii) disallowance of depreciation:\nRs. 3,11,24,473/-; (iii) disallowance

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

58,27,68,190/- only. The return of income was processed under section 143(1) of the Act wherein the CPC disallowed

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 under Section 40(a)(ia), and addition towards Form 26AS mismatch. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Shri Sriram Seshadri, C.A., 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 06.12.2024, submitted