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

801A of the I.T. Act. The assessee, therefore, prays the Hon'ble ITAT to kindly dismiss the appeals filed by the Revenue. 9. We have heard the rival submissions and perused the material on record. In the present case, the sole objection of the AO is that the infrastructure facility created by the assessee -- the formation of ‘Venkatadri Reservoir Bund

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

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

801A. 23.2 From the above reading, it is clear that prior to the insertion of the Finance Act, 2007, there was no such Explanation, and it was only by way of the Explanation that a specific category of persons executing works contracts was excluded from Section 80IA of the Act. This exclusion applied only to works contracts' awarded

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ष / Assessment Years: 2006-07, 2007-08 & 2008-09)

801A(4) of the Act. 7.9 At this juncture, it is important to note that there is a clear difference and distinction between the terms "developer" and "contractor". Further, normally, any "works contract" awarded by the Government to a contractor by way of a tender process would fall under the ambit of the contractor rather than developer. This issue

K.RAHEJA IT PARK (HYDERABAD) PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahushri Assessment Year: 2011-12 K. Raheja It Park ` Dy. Commissioner Of (Hyderabad) Pvt. Ltd., Income-Tax, Hyderabad. Circle – 2(1), Hyderabad. Pan – Aacck 1914G (Appellant) (Respondent) Assessee By: Shri Vijay Mehta & Ms. Aarthi Sathe Revenue By Shri Yvst Sai Date Of Hearing: 18/03/2021 Date Of Pronouncement: 06/05/2021

House Property' offered by the Appellant. Thereafter, the Ld AO., after discussing and verifying the eligibility of the deduction u/s 80-IA(4)(iii) of the Act allowed a deduction under that section to the extent of Rs 13,67,23,850. The matter pertaining to head of taxation of the Income from leasing activities was then subject to litigation

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

801A. The eligible business is defined in section 80IA(1) with reference to the section 80IA(4). Nowhere in any of these sub-sections, does eligible business mean business claiming the deduction u/s 80IA. Therefore, the argument that assessee is not claiming any deduction in the year concerned is of no relevance. (b)Whether or not the 80IA deduction

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

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ष / Assessment Years: 2006-07, 2007-08 & 2008-09)

801A. 23.2 From the above reading, it is clear that prior to the insertion of the Finance Act, 2007, there was no such Explanation, and it was only by way of the Explanation that a specific category of persons executing works contracts was excluded from Section 80IA of the Act. This exclusion applied only to works contracts' awarded

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED, HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED , HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure

DY. COMMSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED., HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

4) shall not be allowed on the said amount. In this regard the assessee humbly submits that no payments as presumed by the CIT-DR were made by the assessee. Further, the assessee company did not debit any expenditure which is not allowable as a deduction. 62. The Assessing Officer at the time of assessment did not find any expenditure