TELANGANA POWER GENERATION CORPORATION LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

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

Bench: Shri Manjunatha G & Shri Ravish Sood

disallowance of contribution to pension and gratuity trust under section 43B of the Act for Rs.21,92,43,000/- disallowance

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)

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

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 Rs. 4,96,92,167/-, without assigning any reason therefor. 3 ITA (TP) 104/Hyd/2022 Sanghi Industries Limited 8. That in the facts and circumstances of the case, the Ld. AO is not justified in determining the tax payable including interest Rs. 60,06,68,444/- without adjusting brought forward losses and unabsorbed depreciation of earlier assessment years

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

92,81,093/- u/s.43B of the Act was made by CPC u/s.143(1) of ITA No.912/Hyd/2024 30 the Act even though the assessee had made all said payments within the stipulated time. This disallowance was also inadvertently retained by the Ld. AO from the income computed u/s.143(1) of the Act. Accordingly, the Ld. AR prayed before the bench

LAURUS LABS LIMITED,VISHAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

disallowance of claim under section 35(2AB) of the Act in respect of clinical trials. This issue also covered by the decision of the Hon'ble Gujarat High Court in the case of Cadila Healthcare (supra). While respectfully following the said decision, a coordinate Bench of this Tribunal held in the case of Aurobindo Pharma Limited in ITA No. 352/Hyd/2023

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. LAURUS LABS LIMITED, VISAKHAPATNAM

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

disallowance of claim under section 35(2AB) of the Act in respect of clinical trials. This issue also covered by the decision of the Hon'ble Gujarat High Court in the case of Cadila Healthcare (supra). While respectfully following the said decision, a coordinate Bench of this Tribunal held in the case of Aurobindo Pharma Limited in ITA No. 352/Hyd/2023

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. LAURUS LABS LIMITED, VISAKHAPATNAM

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

disallowance of claim under section 35(2AB) of the Act in respect of clinical trials. This issue also covered by the decision of the Hon'ble Gujarat High Court in the case of Cadila Healthcare (supra). While respectfully following the said decision, a coordinate Bench of this Tribunal held in the case of Aurobindo Pharma Limited in ITA No. 352/Hyd/2023

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. LAURUS LABS LIMITED, VISAKHAPATNAM

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

disallowance of claim under section 35(2AB) of the Act in respect of clinical trials. This issue also covered by the decision of the Hon'ble Gujarat High Court in the case of Cadila Healthcare (supra). While respectfully following the said decision, a coordinate Bench of this Tribunal held in the case of Aurobindo Pharma Limited in ITA No. 352/Hyd/2023

ITO (INTERNATIONAL TAXATION)-1, HYDERABAD vs. KESAVA KUMAR KUNAPUREDDY, HYDERABAD

In the result, the appeal of the Revenue is dismissed

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

disallowed deduction claimed under Section 54F of the Act for Rs. 7,33,96,000/- on the ground that, the assessee has failed to invest unutilized amount of capital gain derived from sale of property in the Capital Gain Deposit Account Scheme on or before filing of return of income under Section 139(1) of the Act, and also failed

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

GRANULES INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

disallowance of deduction under section 10B of the Act which needs to be adjudicated along with the other grounds taken by the assessee on validity of the reopening of the assessment and therefore, in our considered view additional grounds filed by the assessee needs to be admitted. Thus, we admit the additional grounds filed by the assessee for adjudication

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

92 and Section 80IB r.w.s 80IA(8) of the Act. 19 ITA TP 466/Hyd/2022 and 1301/Hyd/2024 Dodla Dairy Limited. 25. Thereafter, the TPO vide his “SCN”, dated 30.07.2021, inter alia, observed that the chilling units, i.e., the eligible units were not making any actual profit if the chilled milk was transferred by them to the processing plants at rates comprising

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

disallowance computed under section 14A of the Act pertains to computation of income under the normal provisions of the Act and cannot be read into the provisions of section 115JB of the Act pertaining to levy of minimum alternate tax and there is no express provision in clause (f) of Explanation 1 to section 115JB of the Act to that

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

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

disallowing 50% of the expenditure, despite TPO accepting similar expenditure to be at arm's length to the extent of its actual cost in subsequent assessment year (AY 2022-23) 5. The lower authorities have erred in making an adjustment towards interest on loans advanced to subsidiaries despite the fact that, under the terms of the loan agreement, no interest

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

disallowing 50% of the expenditure, despite TPO accepting similar expenditure to be at arm's length to the extent of its actual cost in subsequent assessment year (AY 2022-23) 5. The lower authorities have erred in making an adjustment towards interest on loans advanced to subsidiaries despite the fact that, under the terms of the loan agreement, no interest

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

disallowing the relief claimed by the Appellant of INR 31,48,038 towards foreign tax credits under section 90/91 of the Act, without considering assessee's submission and documentary evidence. 19. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in disregarding Assessee's claim for additional relief

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Section 143(3) of the Income-tax Act, 1961 dated 18.03.2014 on the ground that, the assessee has not challenged the additions made by the A.O. and accepted the disallowances. 5. Aggrieved by the assessment order, the assessee preferred appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee challenged the addition made towards disallowance of foreign