MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeals filed by the assessee for assessment years 2019-20 and 2020-21 are partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

68,95,756 - 14,09,92,643 2020-21 5,12,22,731 3,27,38,075 1,02,22,479 48,55,404 2,67,81,999 - 12,58,20,688 2021-22 5,57,69,012 1,62,07,177 58,57,556 41,70,416 3,24,22,875 9,03,945 11,53,30,981 Total

ACIT., CENTRAL CIRCLE-2(4), , HYDERABAD vs. M/S. MAITHRI LABORATORIES PRIVATE LIMITED, HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon'Ble

e) of the Act. 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of bulk drugs and formulation product. A search and seizure operation under Section 132 of the Income Tax Act, 1961 was carried out in M/s. MSN Group of cases on 24.02.2021. The appellant M/s. Maithri Laboratories

ACIT CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED ZEESHANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

3 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd cash for acquiring 80 acres of land at Machanapally Revenue Village and Gram panchayat by his family members. 11. On the facts and in the circumstances of the case, and in law, the learned CIT(Appeals) erred in law in not following the ratio laid down

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED IMRANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

3 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd cash for acquiring 80 acres of land at Machanapally Revenue Village and Gram panchayat by his family members. 11. On the facts and in the circumstances of the case, and in law, the learned CIT(Appeals) erred in law in not following the ratio laid down

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED IMRANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

3 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd cash for acquiring 80 acres of land at Machanapally Revenue Village and Gram panchayat by his family members. 11. On the facts and in the circumstances of the case, and in law, the learned CIT(Appeals) erred in law in not following the ratio laid down

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED IRFANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

3 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd cash for acquiring 80 acres of land at Machanapally Revenue Village and Gram panchayat by his family members. 11. On the facts and in the circumstances of the case, and in law, the learned CIT(Appeals) erred in law in not following the ratio laid down

INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE2(1), HYDERABAD

In the result, appeal of the Assessee for the assessment year 2021-2022 is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.943 & 1359/Hyd/2024 Assessment Years 2020-2021 & 2021-2022 Indeed India Operations The Acit, Private Limited, Vs. Circle-2(1), Hyderabad – 500 081. Hyderabad. Telangana Pan Aadci5931J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Mahima Goud, Advocate राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

68,62,731 towards interest on outstanding receivables. 2. On the facts and in the circumstances of the case and in law, the Ld. TPO erred and the Hon'ble DRP further erred in upholding/confirming the action of the Ld. TPO, in rejecting the transfer pricing analysis/study prepared by the Appellant and conducting fresh benchmarking, without appreciating that none

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

13. Without prejudice to the above grounds, the Ld. CIT(A) has failed in fairly appreciating the fact that as per the report of the District Collector, the land in question under transfer is not identifiable in Revenue records and that therefore, there arose business loss, which needs to be given set off. 14. The Ld. CIT(A) ought

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

13. Without prejudice to the above grounds, the Ld. CIT(A) has failed in fairly appreciating the fact that as per the report of the District Collector, the land in question under transfer is not identifiable in Revenue records and that therefore, there arose business loss, which needs to be given set off. 14. The Ld. CIT(A) ought

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

13. Without prejudice to the above grounds, the Ld. CIT(A) has failed in fairly appreciating the fact that as per the report of the District Collector, the land in question under transfer is not identifiable in Revenue records and that therefore, there arose business loss, which needs to be given set off. 14. The Ld. CIT(A) ought

MAITHRI LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Section 2(22)(e) of the Act. However, keeping in\nview the flexibility required in practical business situations, the AO\ntreated the payments made by the assessee company to the above\ntwo companies to the extent of 150% of the purchases made from\nthe recipient companies as the payments made in the ordinary\ncourse of business, and the payments

R.A.K CERAMICS INDIA PRIVATE LIMITED,SAMALKOT vs. DCIT CIRCLE -3(1), HYDERABAD

section 144B of the Act and is liable to be quashed. On the facts and in the circumstances of the case and in law, the Hon'ble Panel erred in upholding the action of the learned Transfer Pricing Officer ('Ld. TPO') / Learned Assessing Officer ('Ld. AO') in proposing an adjustment of INR 1,29,68,545 to the international

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. DEVENDER RAO GORUKANTI, HYDERABAD

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2021-22 Acit,Cc-2(2) Vs Devender Rao Gourkanti Room No.616,6Th Floor . H.No.8-2-293/82/Nl/231 Aaykar Bhawan Mla Mp Colony Basheerbagh Jubilee Hills Hyderabad-500 004 Hyderabad-500 033 Pan : Akepg7452N (Appellant) (Respondent) Assessee By: Shri H.Srinivasulu Revenue By: Shri K.P.R.R.Murthy, Sr.Ar Date Of Hearing: 20.03.2023 Date Of Pronouncement: 31.05.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.06.2022 Of The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad Relating To Ay 2021-22. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Partner In M/S. Yashoda Helathcare Services Pvt.Ltd & Derives Partner’S Remuneration & Interest On Capital. He Filed His Original Return Of Income On 28.12.2021 Declaring Total Income Of Rs.8,56,33,070/- A Search & Seizure Operation U/S. 132 Of The I.T. Act Was Conducted In The Case Of Yashoda Group On 22.12.2020, During Which The Case Of The Assessee Was Also Covered. In Response To Notice U/S. 153A Of The I.T.Act,The Assessee Filed His Return Of Income Admitting Additional

E R Per Shri Rama Kanta Panda (A.M.): This appeal filed by the assessee is directed against the order dated 16.06.2022 of the Learned Commissioner of Income Tax (Appeals)-12, Hyderabad relating to AY 2021-22. 2. Facts of the case, in brief, are that the assessee is an individual and partner in M/s. Yashoda Helathcare Services Pvt.Ltd and derives

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of drugs and pharmaceuticals. A search and seizure operation under Section 132 of the Income Tax Act was carried out in M/s. MSN Group of cases on 24.02.2021. The appellant M/s. MSN Pharmachem Private Limited (hereinafter

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing of drugs and pharmaceuticals. A search and seizure operation under Section 132 of the Income Tax Act was carried out in M/s. MSN Group of cases on 24.02.2021. The appellant M/s. MSN Pharmachem Private Limited (hereinafter

MYADAM KISHAN RAO CHARITABLE TRUST,HYDERABAD vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Manjunatha G., Hon'Ble & Shri K.Narasimha Chary, Hon'Ble

section 12AB(4) of the Act. The Ld.CIT(E) further noted that as per the information available with the records, for the AY. 2017-18, the assessment has been passed u/s. 143(3) of the Act on 12-12-2019, making an addition of Rs. 1 crore u/s. 68 of the Act in respect of the alleged receipt

PRYSMIAN CAVI E SISTEMI SRL INDIA PROJECT OFFICE (FORMERLY PIRELLI CAVI SISTEMI S P A INDIA PROJECT OFFICE),HYDERABAD vs. DCIT,( INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

E Sistemi SRL,\nIndia Project Office, Hyderabad.\nPAN: AABCP2267Q\n(Appellant)\nDy. Commissioner of Income Tax,\nInternational Taxation-2,\nHyderabad.\nVs.\n(Respondent)\nनिर्धारिती द्वारा/Assessee by:\nShri Nitesh Joshi, C.A.\nराजस्व द्वारा / Revenue by:\nShri B. Bala Krishna, CIT-DR\nसुनवाई की तारीख /Date of hearing:\n03/07/2025\nघोषणा की तारीख / Pronouncement:\n14/07/2025\nआदेश/ORDER\nPER MADHUSUDAN SAWDIA, A.M.:\nThese

SUPREME AGRO,HYDERABAD vs. ACIT CENTRAL CIRCLE-3 (1), HYDERABAD

In the result, all the appeals of assessees are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

E R Per Bench : The captioned three appeals filed by different assessees are against the separate orders passed by the learned Commissioner of Income Tax (Appeals) – 11, Hyderabad for the assessment year 2018-19. 2. The grounds raised by the respective assessees in both the appeals i.e. ITA No.119 and 120/Hyd/2022 are same and hence, we are reproducing the grounds