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

68,02,280/- whereas the income of the assessee was computed after assessment at Rs.29,55,62,962/-as per the order passed u/s 143(3). Interestingly after the search was carried out the assessee had filed the return of income declaring ‘nil’ income and sought a refund of Rs. 40,75,88,535/-. For all the three years

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

68,02,280/- whereas the income of the assessee was computed after assessment at Rs.29,55,62,962/-as per the order passed u/s 143(3). Interestingly after the search was carried out the assessee had filed the return of income declaring ‘nil’ income and sought a refund of Rs. 40,75,88,535/-. For all the three years

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

68,02,280/- whereas the income of the assessee was computed after assessment at Rs.29,55,62,962/-as per the order passed u/s 143(3). Interestingly after the search was carried out the assessee had filed the return of income declaring ‘nil’ income and sought a refund of Rs. 40,75,88,535/-. For all the three years

VALUE LABS LLP,HYDERABAD vs. ACIT CIRCLE-8(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Manjunatha. G & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 229/Hyd/2022 ("नधा"रण वष" / Assessment Year: 2009-10) Value Labs Llp, Vs. Acit, Hyderabad. Circle-8(1), [Pan : Aakfv2276K] Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

68,75,25,333/- and that the assessee parked certain funds generated from the export business in two bank accounts as FDs, which accrued some interest amount and was shown in the P & L A/c. Claim of the assessee is that such interest income is directly generated from surplus business funds and, therefore, directly relatable to export oriented business, forming

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

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

68 (SC)  V Jaganmohan Rao Vs. CIT/EPT (1970) 75 ITR 373 (SC)  ITO Vs. Mewalal Dwarka Prasad [1989] 176 ITR 529 (SC) 14. The learned Counsel for the assessee further referring to the decision of the Hon’ble Supreme Court in the case of V Jaganmohan Rao Vs. CIT reported in (1970) 75 ITR 373 (SC), and ITO Vs. Mewalal

ACIT, CIRCLE-17(1), HYDERABAD, HYDERABAD vs. DST WORLDWIDE SERVICES INDIA PVT. LTD., HYDERABAD, HYDERABAD

In the result, Revenue’s appeal is dismissed, while cross objections of the assessee are partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahasstt. Commissioner Of Vs M/S. Dst Worldwide Income Tax, Circle 17(1) Services India Pvt. Ltd Hyderabad Hyderabad Pan: Aaaci7097L (Appellant) (Respondent)

section 10A. 5. Whether on the facts and circumstances of the case, the ORP is right in law in directing the Assessing Officer to take Rs. 21,68

HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, ,HYDERABAD vs. ADDL. COMMISSIONER OF INCOME TAX , RANGE-2, HYDERABAD

In the result, Ground No.6(b) is allowed and Ground

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1613/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2010-11) Hsbc Electronic Data Vs. Addl. C.I.T Processing India (P) Ltd Range-8 Hyderabad Hyderabad Pan:Aaach8235M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Cas Nusrath Farheen & Shyam Agarwal राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 26/03/2025 घोषणा की तारीख/Pronouncement: 27/03/2025 आदेश/Order

68,32,843/- from the profits of the business instead of considering the net amount of Rs.63,66,53,406 credited to profit and loss account for the purpose of computing deduction u/s 10A of the Act”. Page 2 of 10 ITA No 1613 of 2017 HSBC Electronic Data Processing India P Ltd 3. As regards Ground No.6

TNS INDIA PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmantns India (P) Ltd Vs Asstt. Commissioner Of Hyderabad Income Tax, Circle 2(2) Pan:Aabcn2278F Hyderabad (Appellant) (Respondent)

68,77,905/-, but while claiming the deduction u/s 10A, other income was excluded from the total turnover and the export turnover was taken at Rs.65,79,30,795/-. He also observed that the telecommunication charges of Rs.1,08,70,739/- was not reduced from the export turnover which resulted in excess deduction u/s 10A

GOLDSTONE TECHNOLOGIES LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3., HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Goldstone Technologies Vs. Asst. Commissioner Of Ltd., Hyderabad. Income-Tax, Central Circle – 3 Pan – Aaacg 7478F (Now Central Circle – 2(1), Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai Date Of Hearing: 07/10/2021 Date Of Pronouncement: 23/11/2021

68,840/-. 2.1 Thereafter, notice u/s 142(1) along with questionnaire was issued to the assessee on 22/07/2011 against which the ld AR of the assessee filed the information called for. 2.2 On perusal of record, the AO noticed that the assessee company claimed deduction u/s 10A of Rs. 42,10,048/-, but has not furnished any break-up details

AUROBINDO PHARMA LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee is partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 92B of the Act itself had made it abundantly clear that if the assessee is providing the capital financing, including any type of long term or short term borrowing, lending or “guarantee”, purchase or sale etc., then such transaction shall be considered as international transaction. Undoubtedly, the assessee has given Corporate Guarantee on behalf of its AE, which

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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case

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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case

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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case

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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case

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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS 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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS 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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS 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

68 of the I.T.Act. The Hon’ble High Court is of the view that no question of law arises when the Tribunal found that based on the evidences the claim that certain parties advanced amounts is found to be non genuine. The burden of proof as required u/s 68 is totally different than the claim of expenditure. In the case