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

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 of appeal

DILEEP KUMAR SAKAMURI CHENCHU VENKATA,SRIKALAHASTI vs. INCOME-TAX OFFICER, WARD-1(3), TIRUPATI

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

Bench: Us:

234C of the Act Additional Grounds being raised before the Hon'ble ITAT for the first time 5. That on the facts and circumstances of the case the Order under Section 147 rws 144 rws 144B of the Actis bad in law as the Notice under section 148 has been issued beyond the period of limitation prescribed under

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings are\nnot barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section

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)

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

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

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 of the 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)

234C of the Act on the assessed income instead of on the income returned by the Appellant. 20.2 The Ld. AO has erred in levying interest under section 234A and 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

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)

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 according

G R N CONSTRUCTIONS PRIVATE LIMITED,NELLORE vs. DCIT., CIRCLE-1, NELLORE

Bench: Us:

234C of the Income-Tax Act, 1961, under the facts and circumstances of the case. 7. The Appellant craves leave to add, alter, delete or substitute any of the grounds urged above. 8. In the view of the above and other grounds that may be urged at the time of the hearing of the appeal, the Appellant prays that

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 234A, 234B & 234C for levy of interest for the AY under consideration as the same are not applicable since there will be no demand after consideration of taxes.” 3. The grounds raised by the assessee in ITA Nos. 374 to 376/Hyd/2022 for A.Y. 2015-16 to 2017-18 are identical except the amounts involved in and hence

K & R RAIL ENGINEERING LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 234A, 234B & 234C for levy of interest for the AY under consideration as the same are not applicable since there will be no demand after consideration of taxes.” 3. The grounds raised by the assessee in ITA Nos. 374 to 376/Hyd/2022 for A.Y. 2015-16 to 2017-18 are identical except the amounts involved in and hence

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 234A, 234B & 234C for levy of interest for the AY under consideration as the same are not applicable since there will be no demand after consideration of taxes.” 3. The grounds raised by the assessee in ITA Nos. 374 to 376/Hyd/2022 for A.Y. 2015-16 to 2017-18 are identical except the amounts involved in and hence

K & R RAIL ENGINEERING LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 234A, 234B & 234C for levy of interest for the AY under consideration as the same are not applicable since there will be no demand after consideration of taxes.” 3. The grounds raised by the assessee in ITA Nos. 374 to 376/Hyd/2022 for A.Y. 2015-16 to 2017-18 are identical except the amounts involved in and hence

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 234A, 234B & 234C for levy of interest for the AY under consideration as the same are not applicable since there will be no demand after consideration of taxes.” 3. The grounds raised by the assessee in ITA Nos. 374 to 376/Hyd/2022 for A.Y. 2015-16 to 2017-18 are identical except the amounts involved in and hence

VANASOWRABHA ASSOCIATES,WARANGAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, WARANGAL

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

Bench: Shri Laliet Kumar & Shri Manjunatha G

section 234A, 234B and 234C of the Income-Tax Act, 1961, under the facts and circumstances of the case. ITA No.439/Hyd/2023 3 11. The Appellant craves leave to add, alter, delete or substitute any of the grounds urged above. 12. In the view of the above and other grounds that may be urged at the time of the hearing

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

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -3(4), HYDERABAD vs. ROYAL ENGINEERING, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

234C Interest u/s 234D 0 Interest u/s 234F 0 Total Interest 1,96,90,566/- Total tax +Interest = 2,93,41,470/- Less: TDS = 0 Advance tax paid = 0 Tax paid u/s 140A 0 Regular Tax Paid 0 TOTAL TAXES PAID = 0 0 Refund Issued U/s 143(1)/143(3)/154/etc = 2,93,41,470/- Balance tax payable Round

ACE CONSTRUCTIONS,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

234C Interest u/s 234D 0 Interest u/s 234F 0 Total Interest 1,96,90,566/- Total tax +Interest = 2,93,41,470/- Less: TDS = 0 Advance tax paid = 0 Tax paid u/s 140A 0 Regular Tax Paid 0 TOTAL TAXES PAID = 0 0 Refund Issued U/s 143(1)/143(3)/154/etc = 2,93,41,470/- Balance tax payable Round

ACE CONSTRUCTIONS,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

234C Interest u/s 234D 0 Interest u/s 234F 0 Total Interest 1,96,90,566/- Total tax +Interest = 2,93,41,470/- Less: TDS = 0 Advance tax paid = 0 Tax paid u/s 140A 0 Regular Tax Paid 0 TOTAL TAXES PAID = 0 0 Refund Issued U/s 143(1)/143(3)/154/etc = 2,93,41,470/- Balance tax payable Round