INDRANI PRASAD ,NEW DELHI vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, HYDERABAD

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

234B and 234C and penalties under Section 271 (l)(G), 271A and 2718. Section 158 BFA provides [or levy of interest and penalty in cases of search on .or after January 1, 1997. Section 158 BO specifies the authorities competent to make the block assessment. Section 158 BH provides for application of all the other provisions of this Act, except

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

234B, 234C and 234D was levied as per law. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 8 Gainsight Software Private Limited 7. The learned counsel for the assessee, Shri Alisagar Rampurawala, C.A., referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated

CALLIDUSCLOUD (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

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

234B (Tax Effect: ₹1,33,82,860/-) 7.1. Interest wrongly levied. 8. Penalty Proceedings 8.1. Penalty initiated under Section 274 r.w.s. Section 270A is bad in law.” 3. The brief facts of the case are that the assessee, CallidusCloud India Private Limited, is engaged in the business of providing sales support, marketing and consulting services and software development

SAXON GLOBAL INDIA PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

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

234B and 234C of the Act is not leviable and ought to have been waived on the facts of the case. The appellant craves leave of your Honours to add, alter, delete or substitute any of the grounds urged above. In view of the above and other grounds that may be urged at the time of the hearing

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

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

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

234B and 234C of the Act, and the said levy of interest being wholly ought to be deleted. The Appellant craves leave to add, alter, vary, omit, substitute and or amend the shove grounds of appeal at any time before or at the time of hearing of the appeal so as to enable the Honorable Members to decide this appeal

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

234B of the Act without appreciating the fact that tax payable has arisen on account of adjustments made above. 20.3 On the facts and in the circumstances of the case, the Ld. AO erred in initiating penalty proceedings under section 270A of the Act for under- reporting and misreporting of income. The Appellant craves leave to add, alter, vary, omit

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

234B and 234C of the Act. 21. On the facts and in the circumstances of the case and in law, the Ld. AO erred in initiating the penalty proceedings under Section 274 read with 270A of the Act. 7 ITA.No.489/Hyd./2022 The Appellant craves leave to add to, alter, omit or substitute any or all of the above grounds

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

Section Description Notice Issue Date Due Date for Submission Communication Sent date Document Reference ID RESPONSE SUBMITTED Remarks Hash * Value of Remarks ADKPC1537H BRIJESH CHANDWANI 2019-20 2020-21 First Appeal Proceedings 100076180318 250 [ITBA] Hearing Notice u/s 250of Income Tax Act 1961. 08-Mar-2024 15-Mar-2024 ITBA/NFAC/F/APL_1/2023-24/1062268716(1) Your Honors, In response to the notice of hearing

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

reassessment cannot be read into Section 144C more particularly when\nthe provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the\nproceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels\nappearing for the respondent(s)/assessees that the outer time limit under Section

PITTI HOLDINGS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

section 68 r.w.s.115BBE. Assessed us. 143(3) r.w.s.153C of Income tax Act, 1901 Charge interest u/s.234A, 234B, 234C & 234D of the Income tax Act, 1861 as applicable Computation sheet and demand notice enclosed are a part of this order. 15. This Order is passed with prior approval of the Additional Commissioner of Income Tax, Central Range-1, Hyderabad. VYSHNAVI

REPAL RENEWABLES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

234B and Section 234D of the Act while calculating the Appellant's payable demand. Initiation of penalty under Section 270A 4 ITA.Nos.116 & 481/Hyd./2022 8. On the facts and circumstances of the case and in law, the ld. AO erred in initiating penalty proceedings under Section 270A of the Act. The above grounds are independent and without prejudice

REPAL RENEWABLES PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

234B and Section 234D of the Act while calculating the Appellant's payable demand. Initiation of penalty under Section 270A 4 ITA.Nos.116 & 481/Hyd./2022 8. On the facts and circumstances of the case and in law, the ld. AO erred in initiating penalty proceedings under Section 270A of the Act. The above grounds are independent and without prejudice

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes on the above terms

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

reassessment or re-computation, as envisaged in Section 132B(1)(i) of the Act. The Appellant in this regard three orders passed by Hon’ble ITAT Benches viz., (i) ACIT Vs. Narendra N. Thacker [(2016) 45 ITR Trib 188 (Kol)]; (ii) unreported judgement in ACIT Vs. Sajjan Singh and (iii) unreported order in Arun Bansal, Delhi Vs. ACIT, Delhi

LAXMI VENKATA KRISHNA RICE CORPORATION,NALGONDA vs. ITO, WARD-1, SURYAPET

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)

234B of the 1.T.Act; 9) Any other ground/grounds that may be urged at the time of hearing”. 2. Also, the assessee has raised the following additional ground of appeal, which reads as under: "The learned CIT (Appeals) ought to have considered the fact that the notice u/s 148A(b), the order u/s 148A(d) and the notice u/s 148 were

RONAK GUPTA,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(1), HYDERABAD

In the result, all the appeals of assessees are dismissed

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

234B are reproduced as under: 234A. (1) Where the return of income for any assessment year under sub- section (1) or sub-section (4) of section 139, or in response to a notice under sub-section (1) of section 142, is furnished after the due date, or is not furnished, the assessee shall be liable to pay simple interest

SUPREME AGRO,HYDERABAD vs. ACIT CENTRAL CIRCLE-3 (1), HYDERABAD

In the result, all the appeals of assessees are dismissed

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

234B are reproduced as under: 234A. (1) Where the return of income for any assessment year under sub- section (1) or sub-section (4) of section 139, or in response to a notice under sub-section (1) of section 142, is furnished after the due date, or is not furnished, the assessee shall be liable to pay simple interest

KANISHKA GUPTA,,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(1), HYDERABAD

In the result, all the appeals of assessees are dismissed

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

234B are reproduced as under: 234A. (1) Where the return of income for any assessment year under sub- section (1) or sub-section (4) of section 139, or in response to a notice under sub-section (1) of section 142, is furnished after the due date, or is not furnished, the assessee shall be liable to pay simple interest

GRADIENTE INFOTAINMENT LTD,HYDERABAD vs. INCOME TAX OFFICER, WARD 14(5), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1637 & 1651 To 1655 /Hyd/2025 (िनधा"रण वष"/Assessment Years: 2009-10 To 2013-14) Gradiente Infotainment Ltd Vs. Income Tax Officer Hyderabad Ward 14 (5) Pan: Aaccg1241Q Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: N O N E राज" व "ारा/Revenue By:: Shri D. Praveen, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 30/03/2026 घोषणा की तारीख/Pronouncement: 08/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

234B of Rs.4,71,62,160/-. The Appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at the time of hearing of the appeal, so as to enable the Honourable Members to decide this appeal according to law.” 17. The brief facts of the case are that

GRADIENTE INFOTAINMENT LTD,HYDERABAD vs. INCOME TAX OFFICER, WARD 14(5), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1637 & 1651 To 1655 /Hyd/2025 (िनधा"रण वष"/Assessment Years: 2009-10 To 2013-14) Gradiente Infotainment Ltd Vs. Income Tax Officer Hyderabad Ward 14 (5) Pan: Aaccg1241Q Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: N O N E राज" व "ारा/Revenue By:: Shri D. Praveen, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 30/03/2026 घोषणा की तारीख/Pronouncement: 08/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

234B of Rs.4,71,62,160/-. The Appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at the time of hearing of the appeal, so as to enable the Honourable Members to decide this appeal according to law.” 17. The brief facts of the case are that