PRYSMIAN CAVI E SISTEMI S.R.L,HYDERABAD vs. DCIT (INT,TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

145(3) and estimated profit of\nRs.1,54,46,987/- at the rate of 10% on offshore contract receipts of\nRs.15,44,69,874/-. Further, he estimated profit at the rate of 20% on offshore\ncontract service receipts of Rs.47,11,231/-, amounting to Rs.9,42,246/-. While\ncomputing the total income, the Ld. AO adopted the income assessed

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

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

145(3) and estimated profit of\nRs.1,54,46,987/- at the rate of 10% on offshore contract receipts of\nRs.15,44,69,874/-. Further, he estimated profit at the rate of 20% on offshore\ncontract service receipts of Rs.47,11,231/-, amounting to Rs.9,42,246/-. While\ncomputing the total income, the Ld. AO adopted the income assessed

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

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

2,03,91,600/- made under Section 69 of the Income-tax Act, 1961. 69. The next issue that came up for our consideration from ground no. 12 of the assessee's appeal is the addition of Rs. 3,44,80,000/- towards profit earned from sale of land at Lemuru. 70. During the financial year relevant

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

2,03,91,600/- made under Section 69 of the Income-tax Act, 1961. 69. The next issue that came up for our consideration from ground no. 12 of the assessee's appeal is the addition of Rs. 3,44,80,000/- towards profit earned from sale of land at Lemuru. 70. During the financial year relevant

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

2,03,91,600/- made under Section 69 of the Income-tax Act, 1961. 69. The next issue that came up for our consideration from ground no. 12 of the assessee's appeal is the addition of Rs. 3,44,80,000/- towards profit earned from sale of land at Lemuru. 70. During the financial year relevant

SRUTHI RIEDL,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-2, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Sruthi Riedl, Income Tax Officer, Hyderabad Vs. (International [Pan No. Aggpp6953R] Taxation)-2, Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा /Assessee By: Shri H. Srinivasulu, Ar /Revenue By: Ms. T. Vijaya Lakshmi, Cit-Dr राजस्‍वजस्‍व द्वारा सुनवाई ई की तारीखीख/Date Of Hearing: 28/08/2023 घोषणा की तारीखीख/Pronouncement On: 08/11/2023

sections 50C, 50CA.and 50D.” 2. The brief facts of the case are that assessee being an NRI has filed the return of income for the A.Y. 2016 - 17 declaring an income of Rs.18,26,340/- towards income from house property and towards income from short term and long term capital gains and the case was processed. Thereafter, information was received

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

NANDA KISHORE RAVULA,HYDERABAD vs. ADIT (INTERNATIONAL TAX)-2, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.552/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2020-21) Nanda Kishore Ravula Vs. Adit (International Hyderabad Tax)-2 [Pan :Agupr0664F] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Nikhill Tiwari, Ar रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Dr सुिवधई की तधरीख/Date Of Hearing: 26/06/2025 घोर्णध की तधरीख/Date Of 30/06/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.01.2025 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2020-21. 2. The Brief Facts Of The Case Are That The Assessee, An Individual, Filed His Original Return Of Income For The A.Y.2020- 21 On 15.12.2020, Declaring Total Income Of Rs.1,08,11,550/-. Subsequently, The Assessee Filed Revised Return Of Income On 30.03.2021 & Claimed Foreign Tax Credit (“Ftc”) Of 2 Nanda Kishore Ravula

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 - 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 of Gaurav Singh v. Income-tax Officer (Supra) has also reiterated

AMITH VISHNAV GUDIMELLA,HYDERABAD vs. ITO, WARD-12(1), HYDERABAD, HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

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 - 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 of Gaurav Singh v. Income-tax Officer (Supra) has also

SRIDHARAN VENKATANARAYANAN,SECUNDERABAD vs. DCIT., CIRCLE- 12(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.32/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Sri Sridharan Vs. Dy. Commissioner Of Venkatanarayanan Income Tax, Circle 12(1) Secunderabad Hyderabad Pan:Bgaps6316N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A V. Balaji राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 24/03/2025 घोषणा की तारीख/Pronouncement: 27/03/2025 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 - 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 of Gaurav Singh v. Income-tax Officer (Supra) has also reiterated

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 :

2. The brief facts of the case are that the assessee, individual filed her return of income for the A.Y.2017-18 on 05.08.2017, declaring total income of Rs.1,54,33,210/-. Assessment has been completed u/s 143(3) of the Income tax Act, 1961 (“the Act”) on 17.12.2019, accepting the income returned. The assessment has been, subsequently reopened

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

2,49,54,091/- to the\nreturned income of the assessee company and vide his order passed\nunder section 147 r.w.s 144B of the Act, dated 28/03/2022, determined\nthe income of the assessee company at Rs. 111,71,48,621/-.\n8. Aggrieved, the assessee company carried the matter in appeal\nbefore the CIT(A). As the assessee company, despite having

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

2. The Assessing Officer erred in treating ₹21,71,361 comprising ₹18,49,620 received from sale of duty credit scrips under the Foreign Trade Policy and ₹3,21,741 from foreign exchange gain as "income from other sources." These are in fact business-related receipts and form an integral part of the core operations of the appellant. 3. While

SURESH KUMAR VOBBILISETTY,HYDERABAD vs. INCOME TAX OFFICER, INTERNATIONAL TAXATION-2, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1204/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) Shri Suresh Kumar Vs. Income Tax Officer Vobbilisetty, (International Taxation)-2 Hyderabad Hyderabad Pan:Acgpv5441G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca K Hemalatha राज" व "ारा/Revenue By:: Shri Kumar Aditya, Dr सुनवाई की तारीख/Date Of Hearing: 15/01/2025 घोषणा की तारीख/Pronouncement: 07/03/2025 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 - 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 of Gaurav Singh v. Income-tax Officer (Supra) has also reiterated