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

u/s 143(3) of the Income Tax Act, 1961, in short, the Act. Heard both the parties. Case files perused. 2. We first of all advert to the Revenue’s cross appeal ITA No.467/Hyd/2020 challenging correctness of CIT (A)’s action quashing the impugned assessment for want of a valid section 143(2) notice vide following lower appellate discussion

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

200. Subsequently, the CIT assumed jurisdiction under section 263 of the I.T. Act and directed the A.O. (i) to bring to tax the gain on account of foreign exchange fluctuation of Rs.15,46,428 as income from other sources; (ii) to disallow gratuity of Rs.1,32,95,577; and (iii) to disallow expenditure amounting to Rs.2,69,26,757 relatable

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)

200-201 of APB, therefore, as per subsection(1) of section 151 of the Act (as was available on the statute during the year under consideration) no notice under section 148 of the Act could be issued by the AO unless the Joint Commissioner of Income Tax was satisfied on 10 BA Continuum India Private Limited vs. DCIT the reasons

RAGHU SATYANARYANA KOLLU,KODAD vs. ITO., WARD-1, SURYAPET

In the result, both the captioned appeals are allowed in terms of the aforesaid observations

Bench: Us:

reassessment proceedings for the AY 2013-14. 9. On the facts and in the circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the order passed by the learned AO, National Faceless Assessment Centre u/s 147 rws 144 & 1448 of the Act for the AY 2013-14 which is erroneous

RAGHU SATYANARYANA KOLLU,KODAD vs. ITO., WARD-1, SURYAPET

In the result, both the captioned appeals are allowed in terms of the aforesaid observations

Bench: Us:

reassessment proceedings for the AY 2013-14. 9. On the facts and in the circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the order passed by the learned AO, National Faceless Assessment Centre u/s 147 rws 144 & 1448 of the Act for the AY 2013-14 which is erroneous

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G.\Nand\Nshri Ravish Sood\Nआ.अपी.सं /Ita No.917/Hyd/2024\N(निर्धारण वर्ष/Assessment Year:2020-21)\Nshakti Hormann Private\Nlimited,\Nhyderabad.\Nvs. Dcit,\Ncircle-3(1),\Nhyderabad.\Npan: Aadcs4024Q\N(Appellant)\N(Respondent)\Nनिर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao,\Nca\Nराजस्व द्वारा / Revenue By: Ms. U. Mini Chandran,\Ncit-Dr\Nसुनवाई की तारीख /Date Of Hearing: 15/10/2025\Nघोषणा की तारीख / Date Of 19/12/2025\Npronouncement:\Nआदेश / Order\Nper. Ravish Sood, J.M:\Nthe Present Appeal Filed By The Assessee Company Is Directed\Nagainst The Final Assessment Order Passed By The Assessing Officer (For\Nshort, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The\Nincome Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The\N Assessment Year (Ay) 2020-21. The Assessee Company Has Assailed\Nthe Impugned Order Passed By The Cit(A) On The Following Grounds Of\Nappeal Before Us:\N1. On The Facts & In The Circumstances Of The Case, The Final Assessment\Norder Passed U/S 143(3) R.W.S.144C(13) Of The Act Dated 25.07.2024 By\Nthe Ao & Also The Order Passed U/S 92Ca (3) Dt 30.07.2023 By The Tpo\Nare Bad In The Eyes Of Law & Thus, Unsustainable To The Test Of Appeal.\N2.0 The Final Assessment Order Passed U/S 143(3) R.W.S.144C(13) R.W.S.144B\Nis Beyond The Time Limit Prescribed U/S 153 Of The Act.\N2.

200\nbasis points deemed appropriate in the appellant's case.\n4.3 The Ld. AO has erred in holding that the TPO's approach of\nbenchmarking the transaction against LIBOR rates is justified.\n4.4\nThe Ld. AO has erred in holding that the RBI guidelines pertain to FDI\npolicies and are not directly applicable for determining the Arm's length price

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

3 ITO vs. Shiva Kumar Thota deposited an amount of Rs.1.93 crores during the year under consideration, i.e., post demonetization, which was not commensurate with his return of income, initiated proceedings under section 147 of the Act. Order under section 148A(d) of the Act, dated 29/07/2022 was passed by the AO. Thereafter, the AO issued notice under section

INCOME TAX OFFICER, WARD 3(1), HYDERABAD vs. STYPACK PRIVATE LIMITED , HYDERABAD

In the result, the appeal of the revenue is dismissed, while the cross-objection of the assessee company is allowed in terms of our aforesaid observations

Bench: Us:

3. Succinctly stated, the AO based on information gathered from the Insight Portal and the order dated 28.04.2022 passed u/s 148A(d) of the Act, that the name of the assessee company, viz., Stypack Pvt. Ltd. (PAN : AACCS8673G), had surfaced as one of the beneficiaries in the course of search and seizure proceedings conducted u/s

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

200 crore turnover filter: i. Mindtree Limited ii. Great Software Laboratory Private Limited iii. Nihilent Limited iv. LTIMindtree Limited (formerly Larsen & Toubro Infotech Limited) v. Wipro Ltd. vi. Tata Elxsi Limited vii. Infosys Limited viii. Cybage Software Private Limited 4 M/s. Callidus Cloud (India) Private Limited (d) Inclusion of functionally different companies: i. Nihilent Limited ii. LTIMindtree Limited iii. Wipro

INCOME TAX OFFICER, WARD-8(1), HYDERABAD vs. DAGUMATI SWATHI, HYDERABAD

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

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

200/-; and (ii) deposited cash in a Savings Bank account: Rs.1,31,99,724/- but had not filed her return of income for the year under consideration, initiated proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 13/05/2021 was issued by the ITO, Ward-8(1), Hyderabad. 3. As is discernible from the assessment

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

200% under section 35(2AB) of the Act on account of clinical trial expenses incurred stating that the same was not being approved by Department of Scientific Institute and Research (DSIR) in Form 3CL. 8.2. The Ld. AO/DRP has erred in not appreciating that the explanation 1 to Section 35(2AB) specifically includes clinical trial expenses within its ambit

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

200% under section 35(2AB) of the Act on account of clinical trial expenses incurred stating that the same was not being approved by Department of Scientific Institute and Research (DSIR) in Form 3CL. 8.2. The Ld. AO/DRP has erred in not appreciating that the explanation 1 to Section 35(2AB) specifically includes clinical trial expenses within its ambit

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under Page 10 of 48 ITA Nos.1238 of 2019, 12 to 14 of 2020 723, 761 & 762 of 2020 Madhucon Projects Ltd section

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under Page 10 of 48 ITA Nos.1238 of 2019, 12 to 14 of 2020 723, 761 & 762 of 2020 Madhucon Projects Ltd section

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under Page 10 of 48 ITA Nos.1238 of 2019, 12 to 14 of 2020 723, 761 & 762 of 2020 Madhucon Projects Ltd section

ACIT CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under Page 10 of 48 ITA Nos.1238 of 2019, 12 to 14 of 2020 723, 761 & 762 of 2020 Madhucon Projects Ltd section

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under Page 10 of 48 ITA Nos.1238 of 2019, 12 to 14 of 2020 723, 761 & 762 of 2020 Madhucon Projects Ltd section

MADHUCON PROJECTS LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under Page 10 of 48 ITA Nos.1238 of 2019, 12 to 14 of 2020 723, 761 & 762 of 2020 Madhucon Projects Ltd section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

200/- and the same were received back by the appellant firm for Land Syndication Activity. 10. The Ld. CIT (A) failed to appreciate the fact that the deposits for the assessment year under consideration are nothing but the advances returned back which were given by Partner for Land Syndication Activity and it represents opening balances. 11. The Ld.CIT (A) ought