ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute Resolution

AGRO TECH FOODS LIMITED., SEC'BAD,SECUNDERABAD vs. DCIT, CIRCLE-1(1), HYD, HYDERABAD

In the result, appeal in ITA No

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singh

Properties vs. Director of Income- tax (supra). The contention of the assessee in this case was that, the order framed on the directions given by the DDIT u/s 144A of the Act, could not be revised u/s 263 of the Act, as to the extent, the Assessing Officer could not be said to have applied his mind. The Tribunal held

HIGHRADIUS TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -2(1), HYDERABAD

Bench: Us:

Section 143(3) r.w.s 144C(13) r.w.s 144B of the Act, dated 25.02.2024, has carried the matter in appeal before us. 9. We have heard the Ld. Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them

HYDERABAD INFRATECH PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

144C of the Income Tax Act, 1961 ('the Act'), as per the direction of Learned Dispute Resolution Panel-1, Bangalore (“Ld. DRP”) on 28.10.2019 for A.Y. 2015-16. ITA-TP No.1856/Hyd/2019 2 2. The assessee has raised the following grounds of appeal : ITA-TP No.1856/Hyd/2019 3 3. The brief facts of the case are that, the assessee is a company

SRUTHI RIEDL,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-2, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Sruthi Riedl, Income Tax Officer, Hyderabad Vs. (International [Pan No. Aggpp6953R] Taxation)-2, Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा /Assessee By: Shri H. Srinivasulu, Ar /Revenue By: Ms. T. Vijaya Lakshmi, Cit-Dr राजस्‍वजस्‍व द्वारा सुनवाई ई की तारीखीख/Date Of Hearing: 28/08/2023 घोषणा की तारीखीख/Pronouncement On: 08/11/2023

sections 50C, 50CA.and 50D.” 2. The brief facts of the case are that assessee being an NRI has filed the return of income for the A.Y. 2016 - 17 declaring an income of Rs.18,26,340/- towards income from house property and towards income from short term and long term capital gains and the case was processed. Thereafter, information was received

MADHU KUMAR PATEL,HYDERABAD vs. ADIT,(INT. TAXN)-2, HYDERABAD

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

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year:2015-16 Shri Madhu Kumar Patel Vs. A.D.I.T (Intl.Taxation)-2 Hyderabad Hyderabad Pan:Bvdpp3797G (Appellant) (Respondent) Assessee By: Shri K.A. Sai Prasad, Ca Revenue By: Shri Rajendra Kumar, Cit(Dr) Date Of Hearing: 10/11/2022 Date Of Pronouncement: 26/12/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.7.2022 Passed U/S 147 R.W.S. 144C(13) Of The I.T. Act For The A.Y 2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & A Resident Of The U.K. He Filed His Return Of Income On 31.08.2015 Declaring Total Income At Rs.2,91,07,000/- As Income From Long Term Capital Gain.

144C(13) of the I.T. Act for the A.Y 2015-16. 2. Facts of the case, in brief, are that the assessee is an individual and a resident of the U.K. He filed his return of income on 31.08.2015 declaring total income at Rs.2,91,07,000/- as income from Long Term Capital Gain. 3. In this case, information

RAJU SURYANARAYANA ALLURI,USA vs. ITO (INT TAXN)-1, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

144C(13) of the Act on 14.03.2024 at total income of Rs.42,24,600/-. 4. Aggrieved with the order of Ld. AO, the assessee is in appeal before us. The Learned Authorised Representative (“Ld. AR”) submitted that, the assessee had merely entered into an agreement with the developer and did not receive any consideration neither monetary nor in kind during

DST WORLDWIDE SERVICES INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(1), HYDERABAD

In the result, assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singhassessment Year: 2014-15 M/S Dst Worldwide Services Dcit, Circle 17(1) India Private Limited Vs. Hyderabad 5Th Floor, Block B Q City Survey # 109, 110, 111/2 Nanakramguda Village Serilingampally Mandal Gachibowli Rr Dist. Hyderabad 500 032 Pan: Aaac17097L (Appellant) (Respondent) Sh. Aliasger Rampurwala, Ar Asessee By: Revenue By: Smt. Anjala Sahu, D.R. Date Of Hearing: 02/09/2020 Date Of Pronouncement: 30/09/2020 Order Per Smt. P. Madhavi Devi, J.M. This Is Assessee’S Appeal For The A.Y. 2014-15 Against The Final Assessment Order Dated 31.10.2018 Passed U/S 143(3) R.W.S. 92Ca(3) & 144C(13) Of The I.T. Act, 1961. This Appeal Was Taken Up For Hearing On 02.09.2020 Through Video Conferencing & Both The Parties Were Heard.

144C(13) of the I.T. Act, 1961. This appeal was taken up for hearing on 02.09.2020 through Video Conferencing and both the parties were heard. ITA No.2234/Hyd/2018 AY 2014-15 M/s DST Worldwide Services India P Ltd. Hyd. 2. Brief facts of the case are that the assessee company is a subsidiary of DST Healthcare Holdings Inc. and Pacific Ventures

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

144C(13) r.w.s 144B of the Act, dated 03/02/2022 and assessed the total income at Rs. 104,99,80,729/-. While passing the assessment order, the Ld. AO also initiated the penalty proceedings U/s. 270A of the Act for under- reporting of income. Feeling aggrieved by the directions of the Ld. DRP / Assessment Order, the assessee preferred the present appeal

KONY IT SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2014-15 M/S. Kony It Services Vs. Deputy Commissioner Of Private Limited, Income Tax, 9Th Floor, B-6, South Tower, Circle-2(1), Divyasree Orion, Sy. Room No.514, 5Th Floor, No.66/1, Raidurgam, Rr Signature Towers, Opp. Dist., Hyderbad – 500 032. Botanical Garden, Pan: Aaeck 9066 D Kondapur, Hyderabad-84. (Appellant) (Respondent) Assessee By: Sri H. Srinivasulu & Sri Kranthi Palivela Ca, Ars Revenue By: Sri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 26/08/2019 Date Of Pronouncement: 20/11/2019

144C of the Act however, the Ld. Members of the DRP upheld the entire upward adjustment of profit by Rs. 5,38,20,492/- and added to the income of the assessee based on which final assessment order was passed on 29/10/2018 aggrieved by which the assessee is in appeal before us. 3 4. The Ld. TPO observed

KONY INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, appeal of the assessee is partly allowed for statistical purposes as indicated hereinabove

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2014-15 M/S. Kony India Private Vs. Deputy Commissioner Of Limited, Income Tax, Sez Unit Ii, Office Level-7, Circle-2(1), Building No. Ho6, Phoenix Room No.514, 5Th Floor, Info City Private Limited, Signature Towers, Opp. Serilingampally, Hyderabad Botanical Garden, – 500 081. Kondapur, Hyderabad-84. Pan: Aadck 2294 C (Appellant) (Respondent) Assessee By: Sri H. Srinivasulu & Sri Kranthi Palivela Ca, Ars Revenue By: Sri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 26/08/2019 Date Of Pronouncement: 20/11/2019

144C of the Act however, the Ld. Members of the DRP upheld the entire upward adjustment of profit by Rs. 16,96,77,951/- and added to the income of the assessee based on which final assessment order was passed on 29/10/2018 aggrieved by which the assessee is in appeal before us. 4. The Ld. TPO observed in his proceedings

DCIT-1, (INTERNATIONAL TAXATION), HYDERABAD vs. SYAMA REDDY MALIREDDY, HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

144C(3) of the Act on 30.11.2021 disallowing the claim of the assessee u/s 54F, thereby determining the long term capital gains at Rs.7,58,13,772/- 3. Feeling aggrieved by the order passed by the assessing officer, assessee filed appeal before the Ld. CIT(A), who granted part relief to the assessee. 3 Smt. Syama Reddy Malireddy 4. Feeling

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

144C(13) rws 153A of the of Income Tax Act, 1961 [in short, ‘the Act’]. ITA Nos. 186 to 189/Hyd/2021 Heard both the parties. Case files perused. 2. We advert to the various identical issues in the assessee’s instant four appeals. It’s first substantive grievance common in all these four assessment years is that the learned lower authorities

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

144C(13) rws 153A of the of Income Tax Act, 1961 [in short, ‘the Act’]. ITA Nos. 186 to 189/Hyd/2021 Heard both the parties. Case files perused. 2. We advert to the various identical issues in the assessee’s instant four appeals. It’s first substantive grievance common in all these four assessment years is that the learned lower authorities

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX , HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

144C(13) rws 153A of the of Income Tax Act, 1961 [in short, ‘the Act’]. ITA Nos. 186 to 189/Hyd/2021 Heard both the parties. Case files perused. 2. We advert to the various identical issues in the assessee’s instant four appeals. It’s first substantive grievance common in all these four assessment years is that the learned lower authorities

VIVIMED LABS LIMITED,HYDERABAD vs. 500082 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

144C(13) rws 153A of the of Income Tax Act, 1961 [in short, ‘the Act’]. ITA Nos. 186 to 189/Hyd/2021 Heard both the parties. Case files perused. 2. We advert to the various identical issues in the assessee’s instant four appeals. It’s first substantive grievance common in all these four assessment years is that the learned lower authorities

SUDHAKAR REDDY METTU,USA vs. ACIT., INTERNATIONAL TAXATION-1, HYDERABAD

In the result, appeals filed by both the assessees are dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.231/Hyd/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Smt. Lekha Reddy Mettu Vs. Acit (International Usa/Hyderabad Taxation-1) Pan:Bnhpm0166N Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.232/Hyd/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Sudhakar Reddy Vs. Acit (International Mettu, Usa/ Hyderabad Taxation-1) Pan:Bnhpm0447G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Akshay Surana राज" व "ारा/Revenue By:: Shri Jeeval Lal Lavidiya, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 29/05/2024

house within three years. So, it is a violation of the section 54F of the Income Tax Act, 1961. The assessee herself admitted that the construction of villa was not completed till date and occupancy certificate was also not received. The Assessing Officer rejected the explanation offered by the assessee and completed the assessment u/s 147 r.w.s. 144C(13

LEKHA REDDY METTU,USA vs. ACIT., INTERNATIONAL TAXATION-1, HYDERABAD

In the result, appeals filed by both the assessees are dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.231/Hyd/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Smt. Lekha Reddy Mettu Vs. Acit (International Usa/Hyderabad Taxation-1) Pan:Bnhpm0166N Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.232/Hyd/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Sudhakar Reddy Vs. Acit (International Mettu, Usa/ Hyderabad Taxation-1) Pan:Bnhpm0447G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Akshay Surana राज" व "ारा/Revenue By:: Shri Jeeval Lal Lavidiya, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 29/05/2024

house within three years. So, it is a violation of the section 54F of the Income Tax Act, 1961. The assessee herself admitted that the construction of villa was not completed till date and occupancy certificate was also not received. The Assessing Officer rejected the explanation offered by the assessee and completed the assessment u/s 147 r.w.s. 144C(13