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

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

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

DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD vs. BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU, YSR DIST., YSR DIST.

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

House, dated 14.10.2010 Commissioner Raghavachari alongwith of Income Tax, Road, Bellary No. of computation of Central Cirlce- shares: income for the 1(3), Bangalore 1020715960 PAN: financial year 2009- AAAC05753D 10 relevant to Ward: DCIT, CC assessment year 1(3), 2010-11 in the case of BLR/DLC/CC/06 M/s Obula Puram 8/03 Mining Co. (P) Ltd. (page 148-149 of Paper

BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU,KADAPA vs. DCIT, CIRCLE-1(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

House, dated 14.10.2010 Commissioner Raghavachari alongwith of Income Tax, Road, Bellary No. of computation of Central Cirlce- shares: income for the 1(3), Bangalore 1020715960 PAN: financial year 2009- AAAC05753D 10 relevant to Ward: DCIT, CC assessment year 1(3), 2010-11 in the case of BLR/DLC/CC/06 M/s Obula Puram 8/03 Mining Co. (P) Ltd. (page 148-149 of Paper

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

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

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

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

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

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 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

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

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

IVY SOFTWARE DEVELOPMENT SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2(1), HYDERABAD

In the result, the ground no

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

144C(5) dated 22.12.2021 for A.Y. 2017-18. 2. The assessee has raised the following grounds of appeal : IT(TP)A No.73/Hyd/2022 2 IT(TP)A No.73/Hyd/2022 3 IT(TP)A No.73/Hyd/2022 4 3. The facts of the case are that, the assessee is a company engaged in the business of provision of Software Development and Computer Assisted Graphics Design

AFTON CHEMICAL INDIA PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(2), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

144C of the Income Tax Act, 1961 (for short “the Act”), consequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru (“DRP”), assessee filed this appeal. 2. Brief facts of the case are that the assessee is a company engaged in the business of distribution of Afton products (petroleum and lubricant additives) to customers in India, apart from providing