DCIT,CIRCLE-17(1), HYD, HYDERABAD vs. DR. REDDY'S LABOURATORIES LTD., HYD, HYDERABAD

In the result, appeal of the revenue is dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2006-07

144C(5) on 30.09.2010 and the assessing officer based on the directions given by the DRP, passed the assessment order on 01.11.2010. Further, the Assessing Officer initiated penalty proceedings u/s 271(1)(c) of the Act stating that the assessee had made wrong claims under different heads and levied penalty of Rs.34,65,20,080/- which is stated

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

penalty proceedings under section 270A of the Act by alleging that there is under reporting of income by the Appellant.” 3. Apart from that the assessee company has filed before us letters dated 14.07.2023, 21.09.2023 and 22.04.2025, wherein it has raised additional grounds of appeal, which reads as under: Filed on 14.07.2023: “1. On the facts and circumstances

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

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

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

Section 92CA of the IT Act, directions given by DRP u/s 144C(5) of the Act and “Give Effect to Directions u/s 144C order of the TPO dt.19.03.2021, the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act was passed and the total income of the assessee was assessed at Rs.49,99,97,796/-. Thereafter

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

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

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

144C(1) of the Act by issuing the notice of demand u/s. 156 of the Act & penalty notices u/s. 271(1)(c) and 271AAB along with Draft assessment order dated 30.12.2016, which tantamount to passing of Final Assessment Order. 2. Erred in making adjustment u/s. 92CA(3) of the Act for Rs. 4,79,143/- in respect of transaction

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

144C of the Act. 33.7 It is also pertinent to highlights that the statute does not permit the collection of tax beyond what is legitimately due from the assessee. Taxation must be based on liability established under the law, and merely because of a procedural lapse, an assessee cannot be compelled to pay tax that it is not legally required

GSS INFOTECH LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

penalty proceedings u/s. 271(1) (c) r.w.s 274, 271AA & 271BA of the Income Tax Act. The appellant may add, alter or modify any other point to the Grounds of appeal at any time before or at the time of hearing of the appeal. 2.3 The assessee has also filed a petition to admit the following additional grounds: Without prejudice

GSS INFOTECH LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

penalty proceedings u/s. 271(1) (c) r.w.s 274, 271AA & 271BA of the Income Tax Act. The appellant may add, alter or modify any other point to the Grounds of appeal at any time before or at the time of hearing of the appeal. 2.3 The assessee has also filed a petition to admit the following additional grounds: Without prejudice

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, the assessee appeal is allowed

Bench: Shri Inturi Rama Rao & Shri Laliet Kumarvs. Dy. Commissioner Of M/S. Hyundai Motor India Engineering Pvt. Ltd., Income Tax, Circle Hyderabad. 2(2), Hyderabad. Pan Aabcjh7867C Appellant Respondent Appellant By : Shri H. Srinivasulu, Adv. Respondent By : Shri Yvst Sai, Cit-Dr. Date Of Hearing : 27.07.2022. Date Of Pronouncement : 29.07.2022. O R D E R Per Shri Inturi Rama Rao, A.M. : This Is An Appeal Filed By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-2, Hyderabad Dt.05.12.2019 For Assessment Year 2015-16. 2. The Assessee Raised The Following Grounds Of Appeal :

271(1)(c) of the Act. 3.6 Being aggrieved by the above draft assessment order along with demand notice, the assessee filed an appeal before the learned CIT (Appeals) challenging inter alia the validity of assessment order on the ground that the assessee is an eligible assessee, within the meaning of provisions of section 144C

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

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

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH PRIVATE LIMITED),HYDERABAD vs. ACIT., CIRCLE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C(2) 15. Initiating the penalty proceedings u/s 271

ACIT, CIRLCE-5 (1), , HYDERABAD vs. MARKET TOOLS RESEARCH PRIVATE LIMITED , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C(2) 15. Initiating the penalty proceedings u/s 271

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH P. LTD.,),HYDERABAD vs. ACIT, CIRLCE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C(2) 15. Initiating the penalty proceedings u/s 271

ACIT., CIRCLE-5(1) , HYDERABAD vs. MARKET TOOLS & RESEARCH PRIVATE LIMITED, HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

13. Not considering the brought forward MAT credit while Computing the tax liability. Interest and Penalty 14. Imposing interest u/s 234B of the Act on: a. TP adjustment on provision of IT Enabled Services ; and b. TP adjustment arising on account of retrospective amendment to the section 92C(2) 15. Initiating the penalty proceedings u/s 271

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

u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act. Thereafter penalty proceedings under Section 271(1)(c) were

PRAKASH LAL POTLURI,HYDERABAD vs. INCOME TAX OFFICER, (INT TAXN)-2,HYD, HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2015-16 Prakash Lal Potluri, Vs. The Income Tax Officer, Hyderabad. (International Taxation)-2, Hyderabad. Pan : Gnkpp1085B. (Appellant) (Respondent) Assessee By: None Revenue By: Sri M. Vijay Kumar – Cit-Dr Date Of Hearing: 29.02.2024 Date Of Pronouncement: 29.02.2024

penalty proceedings under sections 271(1)(c) and 271F. Despite the assessee's explanations, the Assessing Officer did not accept, as the assessee failed to prove that he had not received the sale consideration from said Anil Kumar and added the income from the sale of land to the return of income, totaling Rs.1,20,00,000/-. 3 Accordingly

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

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuay : 2013-14 Ivy Comptech Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1) Hyderabad. Pan – Aaaci 8884K (Appellant) (Respondent) Assessee By: Shri Prashant Meharchandani Revenue By: Shri R. Dipak Date Of Hearing: 27/04/2021 Date Of Pronouncement: 20/07/2021

144C(13) of the Income-tax Act, 1961 (" Act"), in pursuance of the directions issued by the Dispute Resolution Panel - 1, Bengaluru ("DRP"), on the following grounds: On the facts and in the circumstances of the case and in law, the Learned AO/ learned Transfer Pricing Officer ("TPO") and the DRP has erred in: TRANSFER PRICING MATTERS- 1. Imputing interest