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

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

reassessment proceedings under section 147 of the Act. b) No evidence of any new tangible material has been referred to by the Ld. AO in the reasons for re-opening the assessment and hence, it is a mere change of opinion, and the Ld. AO does not have any reason to believe that income has escaped assessment. c) There

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147 or 263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147 or 263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring

DR.REDDY'S LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, we hold that the Tax Authorities were not justified in apportioning R & D expenditure and ESOP cost to the units which claimed exemption u/s 10B, 80IB and 80IC of the Act

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

10A to the return of income does not accept the negative profit of one 10B unit to aggregate with positive profit of the other unit. This plea of the assessee found acceptance of the Assessing Officer. In otherwords, the main basis on which the assessment was sought to be reopened, was found to be wrong. 10. As regards

DR.REDDY'S LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, we hold that the Tax Authorities were not justified in apportioning R & D expenditure and ESOP cost to the units which claimed exemption u/s 10B, 80IB and 80IC of the Act

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

10A to the return of income does not accept the negative profit of one 10B unit to aggregate with positive profit of the other unit. This plea of the assessee found acceptance of the Assessing Officer. In otherwords, the main basis on which the assessment was sought to be reopened, was found to be wrong. 10. As regards

DR.REDDY'S LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, we hold that the Tax Authorities were not justified in apportioning R & D expenditure and ESOP cost to the units which claimed exemption u/s 10B, 80IB and 80IC of the Act

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

10A to the return of income does not accept the negative profit of one 10B unit to aggregate with positive profit of the other unit. This plea of the assessee found acceptance of the Assessing Officer. In otherwords, the main basis on which the assessment was sought to be reopened, was found to be wrong. 10. As regards

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

10A or section 10AA or section 10B or section 10BA or under any provision of the said Chapter - VI A under the heading "C.-Deduction in respect of certain incomes", no deduction would be allowed to him under the said provision. In plain terms, this sub-section (5) of section 80A of the Act imposes an additional condition for claim

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

10A or section 10AA or section 10B or section 10BA or under any provision of the said Chapter - VI A under the heading "C.-Deduction in respect of certain incomes", no deduction would be allowed to him under the said provision. In plain terms, this sub-section (5) of section 80A of the Act imposes an additional condition for claim

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

10A or section 10AA or section 10B or section 10BA or under any provision of the said Chapter - VI A under the heading "C.-Deduction in respect of certain incomes", no deduction would be allowed to him under the said provision. In plain terms, this sub-section (5) of section 80A of the Act imposes an additional condition for claim

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147, 148, 149 and 153 would give way to the provisions of section 153A of the Act. It was submitted that once the assessee has not claimed the benefit of deduction u/s 80IA in the original return of income, then the same cannot be claimed while filing the return of income in pursuance to the notice issued u/s 153A

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147, 148, 149 and 153 would give way to the provisions of section 153A of the Act. It was submitted that once the assessee has not claimed the benefit of deduction u/s 80IA in the original return of income, then the same cannot be claimed while filing the return of income in pursuance to the notice issued u/s 153A

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147, 148, 149 and 153 would give way to the provisions of section 153A of the Act. It was submitted that once the assessee has not claimed the benefit of deduction u/s 80IA in the original return of income, then the same cannot be claimed while filing the return of income in pursuance to the notice issued u/s 153A

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147, 148, 149 and 153 would give way to the provisions of section 153A of the Act. It was submitted that once the assessee has not claimed the benefit of deduction u/s 80IA in the original return of income, then the same cannot be claimed while filing the return of income in pursuance to the notice issued u/s 153A

KARTHIK KUMAR KYATHAM,NIZAMABAD vs. ITO, WARD-1, ADILABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1658/Hyd/2025

10A) The learned CIT(A) ought to appreciate the fact that the Assessee has purchased a house property for 31,50,000 out of which 25,00,000/- is paid from Housing loan availed from Axis Bank and the remaining 6,50,000 is paid out of Assessee's past savings and as such the addition deserves to be deleted

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:

u/s 143(1) dated 22/03/2022 disallowed the claim of Foreign Tax Credit on the ground that the assessee has not filed Form 67 within the prescribed limit i.e. 31st Dec. 2021 in case of the assessee. The assessee filed Form 67 on 6/8/2022 and challenged the order of the CPC before the learned CIT (A) but could not succeed

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this regard a reference may kindly be made to the assessment order passed by the Assessing officer in the case of the sub contractors. Invariably, the assessments in the cases of the sub-contractors were completed on an estimate basis which clearly indicate that there is no requirement

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this regard a reference may kindly be made to the assessment order passed by the Assessing officer in the case of the sub contractors. Invariably, the assessments in the cases of the sub-contractors were completed on an estimate basis which clearly indicate that there is no requirement

DY. COMMSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED., HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

u/s 40A(3) or u/s 40(a)(ia) of the I.T.Act. In this regard a reference may kindly be made to the assessment order passed by the Assessing officer in the case of the sub contractors. Invariably, the assessments in the cases of the sub-contractors were completed on an estimate basis which clearly indicate that there is no requirement