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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

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

801A(3) are not attracted. Hence, just to maintain consistency with the stand of the revenue und to keep the issue alive, AO has disallowed the deduction u/s. 80IA(4)(i)(c). Apart from that there is no merit in such disallowance. However, the learned CIT(A) has allowed assessee's claim u/s.80lA(4)(i)(c) relying on the order

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(4), HYDERABAD

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

Bench: Shri Manjunatha G. Hon’Ble & Shri K. Narasimha Chary, Hon’Bleassessment Year – 2017-18 Prathima Infrastructure Limited, Vs. The Assistant Commissioner Of Income Tax, Filmnagar, Central Circle – 2(4), Hyderabad. Hyderabad. Pan : Aabcp2098P. (Respondent) (Appellant) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri B. Bala Krishna, Cit-Dr Date Of Hearing: 10.10.2024 Date Of Pronouncement: 27.11.2024

801A(4) of the Act is not fulfilled. The work contract Pranahitha-Chevella Lift irrigation scheme link-IV, package No.10 is actually awarded to M/s.HCC-MEIL-BHEL(Joint Venture) from the Government of Andhra Pradesh, Irrigation & C.A.D. Department vide Agreement No.06/2008-09 dated 02/12/2008. Hence, as per the provisions of section 80IA(4) of the Act, the Joint Venture being a separate entity

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

section 80IA of the Act deduction (supra). We are afraid that such a liberal interpretation would amount to going against the stricter interpretation principle in view of honourable apex court decision (supra). We accordingly conclude both the learned lower authorities have rightly disallowed assessee's 80IA deduction claim involving varying sum(s) (supra) in their respective orders. The same stands

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

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

section 801A of the Act\ndecision (supra). We are afraid that such a liberal interpretation would\namount to going against the stricter interpretation principle in view of\nhonourable apex court decision (supra). We accordingly conclude both the\nlearned lower authorities have rightly disallowed assessee's 801A\ndeduction claim involving varying sum(s) (supra) in their respective\norders. The same stands

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

801A(4) of the Act. Thus, the grounds of appeal filed by the assessee are dismissed.” 6. Feeling aggrieved with the order of LD.CIT(A), the assessee is now in appeal before us. 6.1. First, we will deal with the additional grounds raised by the assessee. 7. Before us, the ld.AR submitted that the assessment order was passed

ACIT., CENTRAL CIRCLE-2(2), HYDERABAD vs. M/S KMC CONSTRUCTIONS LTD, HYDERABAD

iv). AYs 2012-13 to 2017-18, dated 25.08.2023 (ITA Nos 33/Hyd/2017 & Ors.), has held that the assessee company is a developer and entitled to deduction under section 801A(4) of the Act. We deem it apposite to cull out the observations recorded by the Tribunal in its latest consolidated order for AYs 2012-13 to 2017-18, dated

SABIR , SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

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

801A.\n23.2 From the above reading, it is clear that prior to the insertion\nof the Finance Act, 2007, there was no such Explanation, and it\nwas only by way of the Explanation that a specific category of\npersons executing works contracts was excluded from Section\n80IA of the Act. This exclusion applied only to works contracts'\nawarded

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

4. Thereafter, the AO, after making certain additions/disallowances, viz. (i) disallowance under section 14A r.w rule 8D: Rs. 74,92,000/-; (ii) disallowance of the claim of the assessee company for deduction under section 80G w.r.t CSR donations: Rs. 1,88,97,644/-; (iii) disallowance of the claim of deduction of the assessee company under Section 801A

SABIR, SEW 7 PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

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

801A.\n\n23.2 From the above reading, it is clear that prior to the insertion\nof the Finance Act, 2007, there was no such Explanation, and it\nwas only by way of the Explanation that a specific category of\npersons executing works contracts was excluded from Section\n80IA of the Act. This exclusion applied only to works contracts'\nawarded

SABIR, SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

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

801A(4) of the Act.\n\n7.9 At this juncture, it is important to note that there is a clear difference\nand distinction between the terms \"developer\" and \"contractor\". Further,\nnormally, any \"works contract\" awarded by the Government to a\ncontractor by way of a tender process would fall under the ambit of the\ncontractor rather than developer. This issue

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

iv) addition under section 68 in respect\nof alleged bogus transactions with M/s. Lakshin Infradev Pvt. Ltd: Rs.\n1,29,91,000/-, determined he income of the assessee company vide his\norder passed under section 143(3) r.w.s 144B of the Act, dated\n26/09/2021 at Rs. 256,91,48,125/-.\n5.\nAggrieved, the assessee company carried the matter in appeal

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

Disallowance of CSR expenses of Rs. 1,42,97,133/- against the returned income of Rs. 50,81,16,931/-. 2.1 Feeling aggrieved, the assessee raised certain objections before the Ld. DRP. The Ld. DRP, after considering the submissions of the assessee and also going through the material available on record, dismissed the objections raised by the assessee. Thereafter