RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

rectification order passed by the ACIT/CPC u/s 154\ndated 27/09/2022 becomes infructuous. In our considered view, the\nobservation of the learned CIT (A) in para 6.2.8 of his order is beyond the\nscope of powers of the learned CIT (A) because, the CIT (A) does not have any\npower to give any direction or finding in respect of issues

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

rectification order passed by the ACIT/CPC u/s 154\ndated 27/09/2022 becomes infructuous. In our considered view, the\nobservation of the learned CIT (A) in para 6.2.8 of his order is beyond the\nscope of powers of the CIT (A) because, the CIT (A) does not have any\npower to give any direction or finding in respect of issues which

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

APACHE FOOTWEAR INDIA PRIVATE LIMITED,MAMBATTU VILLAGE vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CIRCLE-1(1), TIRUPATI

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

rectification order u/s. 92CA(3) r.w.s. 154 dated 18.02.2021 reducing the enhancement from Rs.15,45,28,798 to Rs.11,72,618/-. 3.4 Accordingly, the income returned was enhanced as per the provisions of section 92CA(3) of the Act by a sum of Rs.11,72,618/- towards arm’s length price determined by the TPO u/s. 92CA

MICROSOFT GLOBAL SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

rectification was sought by the assessee. The final adjustments as per the DRP's directions, totaled to Rs. 91,33,00,000/- for Software Development Services was added to the total income of the assessee and thereafter, passed the assessment order on 22.04.2021 u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act. Thereafter penalty proceedings under Section

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

rectification application under section 154 of the Act or appeal under section 246 of the Act. The assessee is required to choose the right course of action diligently which depends upon different facts and circumstances. 25.5 Nevertheless, the object for making the adjustment in the intimation under section 143(1) of the Act or framing the assessment under section