OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (I) PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

271 has no bearing on the question raised before us. There the concessional scheme tempted the assessee to disclose voluntarily all his concealed income and he agreed to pay the proper tax upon ITA Nos.32/Hyd/2019 & 9 2130/Hyd/2017 it. The agreement there related to the quantification of taxable income but in the present case what is sought to be taxed

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

Transfer Pricing Officer)-1, Hyderabad and an order u/s. 92CA(3) of the Income- tax Act, 1961 was passed by him on 22.01.2021 determining the upward adjustment of Rs.15,45,798/- u/s. 92CA of the Act, mentioning as “assessment order”. 3.3 Subsequently, the TPO passed rectification order u/s. 92CA(3) r.w.s. 154 dated 18.02.2021 reducing the enhancement from Rs.15

INCOME TAX OFFICER, WARD-1, CHITTOOR vs. G VIJAYASIMHA REDDY, BENGALURU

In the result, the appeal of Revenue in ITA

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

penalty proceedings u/s 271(1)C are being initiated.” 7.1. Before us, Ld. DR submitted that the activities of the assessee are in the nature of business as the assessee had entered into the JDA. The ld. DR submitted that the assessee had in fact had entered into JDA, which was akin to partnership, as there was an element

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

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

transfer pricing adjustment of Rs. 95,16,40,000/-. On receipt of the order u/s 92CA(3) from the TPO, draft Assessment Order was completed on 25.12.2019 and the sum proposed by the TPO was added to the income of the assessee. 3. Aggrieved with such draft assessment order, assessee company filed objections with the Dispute Resolution Panel

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

DCIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

D S R INFRASTRUCTUREPRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE- 1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

D S R INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

transferred to the DCIT Central Circle-1(4), Hyderabad vide Pr. CIT-1, Hyderabad‘s order u/s 127 of the Act in F.No.Pr.CIT-1,Hyd/Juris-Local/2020-21 dated 05.03.2021 as per jurisdiction. Thereafter, a notice u/s 142(1) was issued to the assessee on 05.04.2021 through ITBA calling for explanation with respect to the unaccounted cash receipts of Rs.3

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

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

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

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

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

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

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

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

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

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

penalty proceedings u/s. 271(1)(c), 271AA and 271BA of the Income Tax Act. The assessee 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.” 3. The assessee also raised the additional grounds on 19.11.2019 which read as under : “6. The Ld. AO/DRP