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

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

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

3 thereto. Therefore, he submitted that Section 153A differs from Section 147, which clearly indicates that the scheme of provision of Section 153A is different from that of Section 147. In :16: ITA Nos. 1717 to 1720/Hyd/2017 & this regard, he relied upon the following judicial precedents :  DCIT Vs. Eversmile Construction

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

3 of 11 Value Labs LLP, Hyderabad 7. Main plank of argument of learned AR is that the interest earned from parking of surplus funds as Fixed deposits and Current account with banks is directly relatable to the assessee’s export business income and is to be allowed as exemp"on u/s 10A of the Act. According to him, under

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 10 A of the Income Tax Act, 1961. 7. Any other ground that may be urged at the time of hearing the appeal”. 3. Grounds 1 & 7 are general in nature and need no adjudication. 4. As regards Grounds 2 and 3 are concerned, it is the case of the Revenue that the DRP should not have rejected

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

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

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

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

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

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

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

3) and Sec.40(a)(ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3

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

3) and Sec.40(a)(ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3

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

3) and Sec.40(a)(ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3

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

3) and Sec.40(a)(ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3

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

3) and Sec.40(a)(ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3

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

3) and Sec.40(a)(ia) of the I.T.Act. in the case of the sub contractors, as submitted in the earlier paragraphs, the Assessing officer estimated the income rejecting the books of account and, therefore, there is no requirement to look ASR Engg. & Projects Ltd. and to others into the disallowance either u/s 40A(3