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

2. The Appellant denies himself liable to be assessed on a total income of Rs.30,60,57,930/-, as against the income returned an amount being Rs. NIL, under the facts and circumstances of the case. 3. The Appellant denies himself liable to be assessed on a total income under the MAT provisions of an amount being

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

2. The Appellant denies himself liable to be assessed on a total income of Rs.30,60,57,930/-, as against the income returned an amount being Rs. NIL, under the facts and circumstances of the case. 3. The Appellant denies himself liable to be assessed on a total income under the MAT provisions of an amount being

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

2. The Appellant denies himself liable to be assessed on a total income of Rs.30,60,57,930/-, as against the income returned an amount being Rs. NIL, under the facts and circumstances of the case. 3. The Appellant denies himself liable to be assessed on a total income under the MAT provisions of an amount being

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

2(45), the total income of an assessee should be assessed and while assessing total income, all permissible deductions, including deduction under Section 80IA, must be allowed. In this regard, he relied on the decision of the Hon’ble Supreme Court in the case of Goetze (India) Ltd. Vs. CIT reported in (2006) 284 ITR 323 (SC). The learned

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LTD(ERSTWHILE EXCELLENCE DATA RESEARCH PRIVATE LIMITED),CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 Cognizant Technology Solutions Vs. Asst. Commissioner Of India Pvt. Ltd., (Erstwhile Income-Tax, Circle – 17(1), Excellence Data Research Pvt. Hyderabad. Ltd.), Chennai Pan – Aabce 4933C (Appellant) (Respondent)

68,35,769/- under the provisions of section 115JB of the Income-tax Act, 1961 (in short ‘the Act’) and a total income of Rs. 14,19,335/- under the normal provisions of the Act. It had claimed deduction u/s 10A of the Act amounting to Rs. 6,95,70,554/- in the return of income. 2.1 The return

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

2 of 11 Value Labs LLP, Hyderabad Excess provisions reversed of Rs. 27,57,647/-, Bad debts reversed of Rs. 6,35,968/- and the miscellaneous receipts of Rs. 6,96,068/-being the profits u/s 41(1) has direct nexus with profits of export oriented unit, Pursuant to the said order, the learned Assessing Officer passed an order dated

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)

68,103 to the provision of Information Technology enabled services and in doing so, the Ld. AO erred in not granting the benefit of the proviso to section 92C(2) the Act. 2. On the facts and in the circumstances of the case and in law, the Ld. DRP and Ld. AO erred including companies namely TCS e-Serve

M.HANMANTH REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumars.No Appeal In Ita Assessee Revenue A.Y No 1 538/Hyd/2018 Smt. Cheruvu Madhavi, Income Tax 2009-10 L/R Of Smt.Sumitrabai Officer Gundavarapu, Ward 9(2) Hyderabad Hyderabad Pan:Athpg1018L 2 8/Hyd/2021 Smt, Yashoda Income Tax 2009-10 Gundavarapu, Officer Ward-1 R.R Distt Vikarabad Pan:Apkpg0183M 3 14/Hyd/2019 Shri M Hanmanth Acit, Circle 2009-10 Reddy, Hyderabad 4(1) Pan:Achph0874L Hyderabad

10A – shall execute sale deed in favour of agreement holder (C) after receipt of balance consideration. Developer (D) shall ensure the balance payment by C to A – In case of failure by C, the developer shall arrange alternate person – In case of delay the owner 1 to 10 (A) shall get interest 15% p.a 1.11 22 Nominees on behalf

YASHODA GUNDAVARAPU,RR DISTRICT vs. INCOME TAX OFFICER , VIKARABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumars.No Appeal In Ita Assessee Revenue A.Y No 1 538/Hyd/2018 Smt. Cheruvu Madhavi, Income Tax 2009-10 L/R Of Smt.Sumitrabai Officer Gundavarapu, Ward 9(2) Hyderabad Hyderabad Pan:Athpg1018L 2 8/Hyd/2021 Smt, Yashoda Income Tax 2009-10 Gundavarapu, Officer Ward-1 R.R Distt Vikarabad Pan:Apkpg0183M 3 14/Hyd/2019 Shri M Hanmanth Acit, Circle 2009-10 Reddy, Hyderabad 4(1) Pan:Achph0874L Hyderabad

10A – shall execute sale deed in favour of agreement holder (C) after receipt of balance consideration. Developer (D) shall ensure the balance payment by C to A – In case of failure by C, the developer shall arrange alternate person – In case of delay the owner 1 to 10 (A) shall get interest 15% p.a 1.11 22 Nominees on behalf

SUMITRA BAI GUNDAVARAPU,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumars.No Appeal In Ita Assessee Revenue A.Y No 1 538/Hyd/2018 Smt. Cheruvu Madhavi, Income Tax 2009-10 L/R Of Smt.Sumitrabai Officer Gundavarapu, Ward 9(2) Hyderabad Hyderabad Pan:Athpg1018L 2 8/Hyd/2021 Smt, Yashoda Income Tax 2009-10 Gundavarapu, Officer Ward-1 R.R Distt Vikarabad Pan:Apkpg0183M 3 14/Hyd/2019 Shri M Hanmanth Acit, Circle 2009-10 Reddy, Hyderabad 4(1) Pan:Achph0874L Hyderabad

10A – shall execute sale deed in favour of agreement holder (C) after receipt of balance consideration. Developer (D) shall ensure the balance payment by C to A – In case of failure by C, the developer shall arrange alternate person – In case of delay the owner 1 to 10 (A) shall get interest 15% p.a 1.11 22 Nominees on behalf

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

AURONEXT PHARMA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

In the result, appeal of assessee is treated as partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

68,03,509/-. In this regard, the ld.AR submitted that the assessee had filed the rectification application before the Assessing Officer and the result is awaited. He had submitted ITA-TP No. 486/Hyd/2022 that the appropriate direction be issued for earlier disposal of the rectification application. 4.2. Per contra, the ld.DR has no objection for issuing the appropriate direction

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

OPEN TEXT TECHNOLOGIES INDIA PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

section 271AA and 271BA of the Act." 3. The assessee has raised the additional grounds as under : “10(c)(a). Choice of CUP as MAM in present case is unjustified. Without prejudice, application of CUP is not in compliance with provisions of Income Tax Act and Income Tax Rules, 1962.” 4. The additional ground so filed is admissible

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

2) Decision of the High Court of Gujarat in the case of Gujarat Ambuja Exports Ltd., reported in 86 taxmann.com 69. The said decision is rendered in a case where the assessee filed a Writ Petition against the order u/s 147 of the I.T. Act. (3) Decision of the High Court of Rajasthan in the case of Bright Future Gems

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

2) Decision of the High Court of Gujarat in the case of Gujarat Ambuja Exports Ltd., reported in 86 taxmann.com 69. The said decision is rendered in a case where the assessee filed a Writ Petition against the order u/s 147 of the I.T. Act. (3) Decision of the High Court of Rajasthan in the case of Bright Future Gems

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

2) Decision of the High Court of Gujarat in the case of Gujarat Ambuja Exports Ltd., reported in 86 taxmann.com 69. The said decision is rendered in a case where the assessee filed a Writ Petition against the order u/s 147 of the I.T. Act. (3) Decision of the High Court of Rajasthan in the case of Bright Future Gems