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

7 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 8 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 9 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 10 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg

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

7 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 8 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 9 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 10 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg

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

7 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 8 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 9 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad Page 10 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg

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

7), should be submitted along with the return of income. In this regard, she relied upon the decision of the Hon’ble Supreme Court in the case of Commissioner of Customs (Imports), Mumbai Vs. Dilip Kumar and Company, reported in (2018) 95 taxmann.com 327 (SC). She, therefore, submitted that the assessee cannot make any fresh claim in the return

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

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 Sec 10A of the Act, interest earned

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. 21,68,353/- as Communication expenses ignoring the fact that the Assessing Officer had rightly taken the amount of Rs. 39,03,927/- towards communication expenses debited under the head 'Internation Privately Leased

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

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

7. On the other hand, the Ld. DR relied upon the order passed by the DRP and submitted that the DRP had computed the bank guarantee charges in accordance with law and therefore, no interference is called for. 8. We have heard the rival contentions of the parties and perused the material available on record. The issue of whether

CURA TECHNOLOGIES LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD

In the result, the assessee appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 M/S Cura Technologies Vs. Dy. Cit, Circle-1(2), Ltd., Hyderabad. Hyderabad.

section 92-B of the IT Act and the transfer pricing provisions are not applicable as there is no income. Accordingly, we set aside the order passed by the CIT u/s 263 and that of the AO is restored and the grounds raised by the assessee in this regard are allowed.” As held in the above, we are inclined

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

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

7) Decision of the ITAT, Kolkata Bench in the case of Sun Steel Industries Pvt. Ltd. Vs DCIT in ITA No.531/Kol/2016 dated 19.2.2018: ASR Engg. & Projects Ltd. and to others The assessee is in the business of fabrication andgalvanizing and erection of transMIssion towers. It claimed payment of Rs.37 lakhs to the sub contractors. The Hon’ble Tribunal found that

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

7) Decision of the ITAT, Kolkata Bench in the case of Sun Steel Industries Pvt. Ltd. Vs DCIT in ITA No.531/Kol/2016 dated 19.2.2018: ASR Engg. & Projects Ltd. and to others The assessee is in the business of fabrication andgalvanizing and erection of transMIssion towers. It claimed payment of Rs.37 lakhs to the sub contractors. The Hon’ble Tribunal found that

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

7) Decision of the ITAT, Kolkata Bench in the case of Sun Steel Industries Pvt. Ltd. Vs DCIT in ITA No.531/Kol/2016 dated 19.2.2018: ASR Engg. & Projects Ltd. and to others The assessee is in the business of fabrication andgalvanizing and erection of transMIssion towers. It claimed payment of Rs.37 lakhs to the sub contractors. The Hon’ble Tribunal found that

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

7) Decision of the ITAT, Kolkata Bench in the case of Sun Steel Industries Pvt. Ltd. Vs DCIT in ITA No.531/Kol/2016 dated 19.2.2018: ASR Engg. & Projects Ltd. and to others The assessee is in the business of fabrication andgalvanizing and erection of transMIssion towers. It claimed payment of Rs.37 lakhs to the sub contractors. The Hon’ble Tribunal found that

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

7) Decision of the ITAT, Kolkata Bench in the case of Sun Steel Industries Pvt. Ltd. Vs DCIT in ITA No.531/Kol/2016 dated 19.2.2018: ASR Engg. & Projects Ltd. and to others The assessee is in the business of fabrication andgalvanizing and erection of transMIssion towers. It claimed payment of Rs.37 lakhs to the sub contractors. The Hon’ble Tribunal found that

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

7) Decision of the ITAT, Kolkata Bench in the case of Sun Steel Industries Pvt. Ltd. Vs DCIT in ITA No.531/Kol/2016 dated 19.2.2018: ASR Engg. & Projects Ltd. and to others The assessee is in the business of fabrication andgalvanizing and erection of transMIssion towers. It claimed payment of Rs.37 lakhs to the sub contractors. The Hon’ble Tribunal found that

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

7) Decision of the ITAT, Kolkata Bench in the case of Sun Steel Industries Pvt. Ltd. Vs DCIT in ITA No.531/Kol/2016 dated 19.2.2018: ASR Engg. & Projects Ltd. and to others The assessee is in the business of fabrication andgalvanizing and erection of transMIssion towers. It claimed payment of Rs.37 lakhs to the sub contractors. The Hon’ble Tribunal found that