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

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

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

2 Assessing] Officer is erroneous in so far as it is prejudicial to the interests of the revenue, he, may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying

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

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

Bench: Us:

2) of the Act, dated 29.06.2021, was issued to the assessee company. Also, as observed by the AO the return of income filed by the assessee company was thereafter processed vide an intimation issued under Section 143(1)(a) of the Act, dated 30.11.2022, wherein after making 6 HighRadius Technologies Private Limited an addition of Rs. 13,13,770/- under

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 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 , 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

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

ADP PRIVATE LIMITED,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

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.

property to the purchaser on 24.3.2015 when the deed of agreement of sale cum GPA was made and executed. Relying on the provisions of section 2(47) of the I.T. Act, 1961 and considering the fact that substantive compliance of the contract had taken place during the financial year 2014-15, the Assessing Officer held that the capital gain

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

2) of the I. T. Act was issued and served on the assessee. Subsequently, notices were issued to the assessee from time to time and the assessee has submitted her reply through ITBA Module. In the present case, assessee had claimed deduction u/s 54F of Rs.3,63,73,330/- towards purchase of residential property at Hyderabad. However, the claim

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

144C(1) of the Act. The assessee Company submitted a letter on 22/09/2021 accepting the order u/s.144C(2) of the Income Tax Act, 1961. Accordingly, a final assessment order was passed. 4.1. During the course of scrutiny, on going through Form 3CEB, the Assessing Officer noted that assessee has made international transactions amounting to Rs.1473,14,81,020/- and specified

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

144C(1) of the Act. The assessee Company submitted a letter on 22/09/2021 accepting the order u/s.144C(2) of the Income Tax Act, 1961. Accordingly, a final assessment order was passed. 4.1. During the course of scrutiny, on going through Form 3CEB, the Assessing Officer noted that assessee has made international transactions amounting to Rs.1473,14,81,020/- and specified

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD, HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

144C(1) of the Act. The assessee Company submitted a letter on 22/09/2021 accepting the order u/s.144C(2) of the Income Tax Act, 1961. Accordingly, a final assessment order was passed. 4.1. During the course of scrutiny, on going through Form 3CEB, the Assessing Officer noted that assessee has made international transactions amounting to Rs.1473,14,81,020/- and specified

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

144C(1) of the Act. The assessee Company submitted a letter on 22/09/2021 accepting the order u/s.144C(2) of the Income Tax Act, 1961. Accordingly, a final assessment order was passed. 4.1. During the course of scrutiny, on going through Form 3CEB, the Assessing Officer noted that assessee has made international transactions amounting to Rs.1473,14,81,020/- and specified

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