PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO ,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION) , NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLOR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

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)

80G towards CSR expenditure, disallowance under Section 40(a)(ia), and addition towards Form 26AS mismatch. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Shri Sriram Seshadri, 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

M/S VISAKA INDUSTRIES LIMITED,,SECUNDERABAD vs. DCIT, CIRCLE-3(3),, HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2006-07 Dy. Commissioner Of Income- Vs. M/S Visaka Industries Ltd., Tax, Circle – 3(3), Hyderabad. Secunderabad. Pan – Aaacv 7263 K (Appellant) (Respondent) Assessment Year: 2006-07 M/S Visaka Industries Ltd., Vs. Dy. Commissioner Of Income- Secunderabad. Tax, Circle – 3(3), Hyderabad. Pan – Aaacv 7263 K (Appellant) (Respondent)

80G 2,08,094 Eligible profits for deduction u/s 80IB 5,79,10,397 Accordingly, he noted that the deduction allowable is 30% of eligible profits which is worked out at Rs. 1,73,73,119/- (30% of 5,79,10,397), hence, the excess claim of deduction u/s 80IB of Rs. 85,79,135/- was disallowed

DY.CIT, CIRCLE-3(3),, HYDERABAD vs. M/S VISAKA INDUSTRIES LIMITED,, SECUNDERABAD

In the result, appeal of the assessee is dismissed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2006-07 Dy. Commissioner Of Income- Vs. M/S Visaka Industries Ltd., Tax, Circle – 3(3), Hyderabad. Secunderabad. Pan – Aaacv 7263 K (Appellant) (Respondent) Assessment Year: 2006-07 M/S Visaka Industries Ltd., Vs. Dy. Commissioner Of Income- Secunderabad. Tax, Circle – 3(3), Hyderabad. Pan – Aaacv 7263 K (Appellant) (Respondent)

80G 2,08,094 Eligible profits for deduction u/s 80IB 5,79,10,397 Accordingly, he noted that the deduction allowable is 30% of eligible profits which is worked out at Rs. 1,73,73,119/- (30% of 5,79,10,397), hence, the excess claim of deduction u/s 80IB of Rs. 85,79,135/- was disallowed

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

80G and 80GGB], the deduction u/sec.80IA is allowable to the extent of Rs.43,04,93,491/- only and the balance amount of Rs.5,58,33,404/- is disallowed u/sec.80IA of the Act and made the addition accordingly and assessed the total income of the assessee at Rs.5,58,33,404/- vide order dated 31.03.2016 passed u/sec.143(3) r.w.s.153A

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

80G and 80GGB], the deduction u/sec.80IA is allowable to the extent of Rs.43,04,93,491/- only and the balance amount of Rs.5,58,33,404/- is disallowed u/sec.80IA of the Act and made the addition accordingly and assessed the total income of the assessee at Rs.5,58,33,404/- vide order dated 31.03.2016 passed u/sec.143(3) r.w.s.153A

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.

5. The Ld. DRP/TPO erred in not appreciating that the amendment to section 92B would not apply to the year under consideration as it was inserted on a later date. The amendment has to be interpreted as prospective in nature. 6. The Ld. DRP/TPO erred in not appreciating the fact that Rain CII Carbon, LLC (RCC') had also provided guarantee