PRYSMIAN CAVI E SISTEMI SRL INDIA PROJECT OFFICE (FORMERLY PIRELLI CAVI SISTEMI S P A INDIA PROJECT OFFICE),HYDERABAD vs. DCIT,( INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

reassessment, the Ld. AO rejected the books\nof accounts of the assessee under section 145(3) and estimated profit of\nRs.1

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

145 is not correct and bad-in- law. 16. The Ld. GIT (A) erred in upholding that the Ld. AO estimating the income of the assessee at an Ad hoc percentage of 8% of turnover is 3 Bilwa Infrastructure Limited vs. ITO un-reasonable and not based on comparative results in the similar line of business

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

reassessment was within the prescribed time and squarely falls within the framework of section 147, Therefore, the action of the AO in reopening the assessment is held to be valid and in accordance with law. Accordingly, grounds of appeal pertaining to this issue are dismissed and not allowed. 5.2. The appellant has challenged against the addition

SRESTA NATURAL BIOPRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.711/Hyd/2024 Assessment Year 2020-2021 Sresta Natural Bioproducts Private Limited, Hyderabad. The Dcit, Circle-3(1), Vs. Pin – 500 081. Hyderabad – 500 081. Telangana. Telangana. Pan Aahcs9571J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca P Murali Mohan Rao राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 11.12.2025 घोषणा की तारीख/Pronouncement: 19.12.2025 आदेश/Order

145 of the Act. 5 ITA.No.711/Hyd./2024 5.6. The Ld. TPO ought to have appreciated the fact that sales to AE includes a substantial profit element with interest aspect being embedded in it and therefore, interest on receivables cannot be coined as a separate "international transaction' as envisaged u/s 92B of the Act. 5.7. The Ld. AO ought

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

145 of the Act and ought to have deleted the estimated income. 14. The Ld. CIT (A) erred in upholding that the Ld. AO estimating the income of the assessee at an Ad hoc percentage of 8% of turnover is un-reasonable and not based on comparative results in the similar line of business. 15. The Ld. CIT(A) ought

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

145 of the Act. 1.3. Ought to have appreciated the fact that the outstanding receivables are accrued from the sale of services rendered to the AE during the normal course of business and hence it cannot be equated to the term 'capital financing' as interpreted in section 92B of the Act. 1.4. Ought to have appreciated the fact that

MADHUSUDAN REDDY PASHAM,HYDERABAD vs. ACIT, CIRCLE-9(1),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Manjunatha G & Shri Ravish Sood

145 credits u/sec.68 of the IT Act 8. Aggrieved by the assessment orders dated 24.12.2018, the assessee preferred appeals before the learned CIT(A). Before the learned CIT(A), during the course of appellate proceedings, the appellant has filed written submissions consisting of copies of revised computation of income, trading and Profit & Loss account and cash flow statement. The learned

MADHUSUDAN REDDY PASHAM,HYDERABAD vs. ACIT, CIRCLE-9(1),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Manjunatha G & Shri Ravish Sood

145 credits u/sec.68 of the IT Act 8. Aggrieved by the assessment orders dated 24.12.2018, the assessee preferred appeals before the learned CIT(A). Before the learned CIT(A), during the course of appellate proceedings, the appellant has filed written submissions consisting of copies of revised computation of income, trading and Profit & Loss account and cash flow statement. The learned

MADHUSUDAN REDDY PASHAM,HYDERABAD vs. ACIT, CIRCLE-9(1), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Manjunatha G & Shri Ravish Sood

145 credits u/sec.68 of the IT Act 8. Aggrieved by the assessment orders dated 24.12.2018, the assessee preferred appeals before the learned CIT(A). Before the learned CIT(A), during the course of appellate proceedings, the appellant has filed written submissions consisting of copies of revised computation of income, trading and Profit & Loss account and cash flow statement. The learned

RAYUDU LABORATORIES LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.725/Hyd/2025 Assessment Year 2020-2021 Rayudu Laboratories The Dcit, Limited, Hyderabad. Vs. Central Circle-2(4), Pin – 500 036. Telangana. Hyderabad. Pan Aabcr8021N (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: -None- राज" व "ारा /Revenue By: Kritika Jaiswal, Sr. Ar

reassessment with a proper hearing. Additionally, a stay on the existing demand until the resolution of this appeal is requested. 9. For these reasons and such other reasons that may be submitted at the time of hearing of the case, the appellant prays that the respected Commissioner of Income Tax (Appeals), Hyderabad: i. Quash the Orders passed u/s.250

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

reassessment proceedings, wherein it was stated\nthat though the assessee company had purchased the power plant but\nhad not put to use the same for its commercial operation and not\ngenerated any income, therefore, it was not entitled for claiming\ndepreciation on the same, Page 145-147 of APB. Also, it was submitted\nby the Ld. CIT-DR that

ADALA BHANU REKHA,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.583/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18) Adala Bhanu Rekha Vs. Dcit Hyderabad Circle-6(1) [Pan : Accpa8679F] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Bg Reddy, Ar रधजस् व द्वधरध/Revenue By:: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 25/11/2024 घोर्णध की तधरीख/Date Of 05/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31/03/2024 Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)], National Faceless Appeal Centre (Nfac), Delhi, Relating To A.Y.2017-18 On The Following Grounds :

145 taxmann.com 37(SC). 6. The learned Counsel for the assessee further referring to the reasons given by the Ld.CIT(A) to sustain the additions made by the Assessing Officer towards disallowance of deduction u/s 54F of the Act submitted that, although the assessee is having multiple properties, but except one house, remaining properties are commercial properties

RATNA INFRASTRUCTURE PROJECTS PRIVATE LIMITED,HYDERABAD vs. ITO, WARD-3(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2012-13 Ratna Infrastructure Projects Vs. The Income Tax Officer, Ward –3(3), Private Limited, Hyderabad. Hyderabad. Pan : Aadcr5836P. (Assessee) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 20.01.2025 Date Of Pronouncement: 12.02.2025

145 taxmann.com 37(SC), wherein it was held that where at the time original assessment u/s 143(3), specific queries were raised by Assessing Officer, which were duly answered by assessee company and thereafter assessment order was passed, it was not open for revenue to reopen assessment on same issue and, thus, impugned reassessment proceedings initiated on mere change

LANCO ENTERPRISE PRIVATE LIMITED ,GURGAON vs. DCIT, CIRCLE-5(1), HYDERABAD (ERSTWHILE DCIT, CIRCLE-16(1)), HYDERABAD ,, HYDERABAD

In the result, ITA Nos. 236 & 237/Hyd/2023 are allowed for statistical purposes and ITA No

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Chary

145(3) of the Act, and the income is estimated @20% on gross receipts. 18. The appellant may, add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal at anu time before or at the time of hearing of the appeal”. 7. The learned Counsel for the assessee submitted

LANCO ENTERPRISE PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-5(1), HYDERABAD (ERSTWHILE DCIT, CIRCLE-16(1), HYDERABAD, HYDERABAD

In the result, ITA Nos. 236 & 237/Hyd/2023 are allowed for statistical purposes and ITA No

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Chary

145(3) of the Act, and the income is estimated @20% on gross receipts. 18. The appellant may, add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal at anu time before or at the time of hearing of the appeal”. 7. The learned Counsel for the assessee submitted

LANCO ENTERPRISE PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-5(1), HYDERABAD (ERSTWHILE DCIT, CIRCLE-16(1)), HYDERABAD ,, HYDERABAD

In the result, ITA Nos. 236 & 237/Hyd/2023 are allowed for statistical purposes and ITA No

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Chary

145(3) of the Act, and the income is estimated @20% on gross receipts. 18. The appellant may, add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal at anu time before or at the time of hearing of the appeal”. 7. The learned Counsel for the assessee submitted

RAIN CEMENTS LIMITED, HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2008-09 M/S. Rain Cements Ltd Vs. Dy. Commissioner Of (Formerly Known As Rain Income Tax, Circle 3 (1) Cii Carbon (India) Ltd Hyderabad Hyderabad Pan:Aabcr8858F (Appellant) (Respondent) Assessee By: Advocate Prathishta Singh & Advocate Deepak Chopra Revenue By: Dr.Rajendra Kumar, Cit-Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 24.03.2017 Passed U/S 143(3) R.W.S. 144C(5) R.W.S. 260 Of The I.T. Act For The A.Y 2008-09. 2. This Appeal Was Earlier Decided By The Tribunal Vide Order Dated 18.10.2019. Subsequently Vide Ma No.15/Hyd/2020, Dated 23.3.2021, The Tribunal Recalled The Entire Order For Fresh Adjudication. Therefore, This Is A Recalled Matter.

reassessment proceedings, there is no additional tax liability and that Appellant is liable to pay tax under the provisions of Minimum Alternative Tax (no adjustment made to the book profits) and thus the question of income having escaped assessment does not arise. Corporate Tax Matters: 17. The d A0/DRP erred in assuming the finance charges for loans taken

SONALI VERMA,SECUNDERABAD vs. ITO., WARD-12(6), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, Gआ.अपी.सं /Ita No.778/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Smt. Sonali Verma Vs. Income Tax Officer Secunderabad Ward 12 (6) Pan:Amnpv3410A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sk Chaturvedi, Ca राज" व "ारा/Revenue By:: Shri Gurpreet Singh Sr.Ar सुनवाई की तारीख/Date Of Hearing: 23/07/2025 घोषणा की तारीख/Pronouncement: 30/07/2025 आदेश/Order

145 taxmann.com 235 (Bangalore - Trib.), [ITA No.680/Bang/2022 order dated 06.09.2022]; Sonakshi Sinha v. CIT (Appeals) [2022] 142 taxmann.com 414/197 ITD 263 (Mumbai - Page 7 of 12 ITA 778 of 2025 Sonali Verma Trib.)/[ITA no.1704/Mum/2022 order dated 20th September, 2022] and host of other judgments referred to and relied upon.” 7. The Jabalpur Bench of the Tribunal in case