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

154,70,02,126 13,00,86,779 Closing debit balance 299,95,35,547 1,80,15,229 Excess payments during the 242,51,01,857 1,80,15,228 year (sales + payments – purchases – receipts) Less: Additional 50% of 97,51,822 26,68,051 purchases in addition to 100% treated as “advance or loan” constituting deemed dividend Aggregate

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

154,70,02,126 13,00,86,779 Closing debit balance 299,95,35,547 1,80,15,229 Excess payments during the 242,51,01,857 1,80,15,228 year (sales + payments – purchases – receipts) Less: Additional 50% of 97,51,822 26,68,051 purchases in addition to 100% treated as “advance or loan” constituting deemed dividend Aggregate

MAHESWARI MINING & ENERGY PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri K. Narasimha Charyassessment Years: 2016-17 Maheswari Mining & Vs. Asst. Commissioner Of Energy Pvt. Ltd., Income-Tax, Hyderabad. Circle – 16(2), Hyderabad. Pan – Aagcm0805N (Appellant) (Respondent) Assessee By: S/Shri Y. Ratnamkar& B. Satyanarayana Murthy Revenue By: Shri Y.V.S.T. Sai Date Of Hearing: 21/04/2022 Date Of Pronouncement: /04/2022

section nor the circular stipulates that the deduction of 15% shall be allowed only for the period after the notification of backward area. 13) Coming to the case of the assessee, the learned Counsel for the assessee submitted that the assessee company set up two solar power plants one at Peerampalli village and the other at Kothagudi

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

68 of the Act. In view of the foregoing discussion, we uphold the order of the CIT(Appeals) in deleting the addition of Rs. 1,29,91,000/-. The Ground of appeal No. 5 raised by the revenue is dismissed in terms of our aforesaid observations. 29. Resultantly, the appeal filed by the Revenue in ITA No. 1083/Hyd/2024

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

section 2(22)(e) and keeping in view\nthe flexibility required in practical business situations, the AO treated\nthe payments made by the appellant company to the extent of 150%\nof the purchases made from the recipient companies as the payments\nmade in the ordinary course of business and the payments made in\nexcess of such

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

1,95,03,644\n| Less: Receipts\n| 154,70,02,126\n| Closing debit balance\n| 299,95,35,547\n| Excess payments during the\n| year\n| (sales + payments – purchases\n| receipts)\n| 242,51,01,857\n| Less: Additional 50%\n| of purchases in addition to 100%\n| 97,51,822\nA/c of MSN\nOrganics

RAVI RAMBABU,HYDERABAD vs. ACIT., CENTRAL CIRCLE 2(3), HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 651/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Ravi Rambabu, Vs. Assistant Commissioner Hyderabad. Of Income Tax, Circle-2(3), Pan: Abspr3702P Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Rectification Order Dated 28.03.2025 Passed By The Cit (Appeals) Under Section 154 Of The Income-Tax Act, 1961 (For Short, “Act"), Dated 28.03.2025, Which In Turn Arises From The Order Passed By The Cit(A) Disposing Of The Assessee’S Appeal, Vide His Order Dated 29.01.2025. The Assessee Has Assailed The Impugned Order Passed By The Cit(A)

68 or section 69 or section 69A or section 69B or section 69C or section 69D of the Act are not applicable to the appellant's case and that charging of tax u/s 115BBE of the Act in the appellant's case is unlawful. 9. Without prejudice to other grounds, the Ld. CIT(A) ought

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, three appeals i

154 of the Act, while deciding the appeal filed by the\nassessee against the order passed by the Assessing Officer u/s\n143(1)/143(3) of the Act. Therefore, in our considered view, the findings\nor directions given by the learned CIT (A) in Para 6.2.8 for the A.Y 2020-\n21 is beyond the scope of the powers

ACIT, CENTRAL CIRCLE-3(1), HYDERABAD vs. SRI CHAITANYA EDUCATIONAL COMMITTE, VIJAYAWADA

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

154, thus arriving at a total income of Rs.26,11,20,759/-. It is however seen that the appellant has not filed any appeal against the said rectification order nor furnished any submissions with regard to the said addition in the present appellate proceedings. Brief facts of the case are that the appellant society was constituted

DR. REDDYS LABORATORIES LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-17(1), HYDERABAD, HYDERABAD

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

Bench: Shri Laxmi Prasad Sahu & Shri K.Narasimha Charyassessment Years: 2007-08 Dr.Reddy’S Laboratories Vs. Dcit,Circle-17(1) Limited Hyderabad 8-2-337, Road No.3 Banjara Hills Hyderabad-500 034

1) confirmed the DRP direction and held that corporate overhead should be allocated, however, the Hon'ble ITAT held that net corporate overhead expenditure should be allocated. However, in so far as tax holiday benefits in respect of other 3 units were not before the ITAT as it was not part of the Final Assessment Order. Hight Court 13. Aggrieved

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

sections": [ "Sec. 143(1)", "Sec. 271D", "Sec. 154", "Sec. 250", "Sec. 11", "Sec. 12", "Sec. 10B", "Sec. 119(2)(b)", "Sec. 269SS", "Sec. 273B", "Sec. 68

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

154 and Explanation 1 (f) to section 115JB being squarely covered, the same cannot be found fault with. We are of the considered view that the Miscellaneous Petition filed by the revenue under section 254(2) of the Act was wholly misconstrued. The Tribunal has distinguished the case of Sobha Developers (supra) relied upon by the revenue with

NAVDURGA TRANSPORT COMPANY,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(1), HYDERABAD

Appeal is allowed in terms of our aforesaid observations

Bench: Us:

154 r.w.s 147 of the Act, dated 30/06/2022, had rectified the assessment order passed by him under section 147 r.w.s 144 of the Act, dated 31/03/2022, and had observed that the addition of Rs. 2,54,59,579/- made by him under section 69A of the Act was as per section 115BBE

NAVDURGA TRANSPORT COMPANY,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(1), HYDERABAD

Appeal is allowed in terms of our aforesaid observations

Bench: Us:

154 r.w.s 147 of the Act, dated 30/06/2022, had rectified the assessment order passed by him under section 147 r.w.s 144 of the Act, dated 31/03/2022, and had observed that the addition of Rs. 2,54,59,579/- made by him under section 69A of the Act was as per section 115BBE

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

154 of the Act, while deciding the appeal filed by the\nassessee against the order passed by the Assessing Officer u/s\n143(1)/143(3) of the Act. Therefore, in our considered view, the findings\nor directions given by the learned CIT (A) in Para 6.2.8 for the A.Y 2020-\n21 is beyond the scope of the powers

THATI SATISH KUMAR,HYDERABAD vs. ITO, WARD-1(12), HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

154 r.w.s. 147 of the Act. Admittedly, both the appeals filed by the assessee before the Ld. CIT(A) are inter-connected i.e. one on the additions made by the A.O. under Sections 68 and 69 of the Act, and its sustainability, and the other one is application of higher rate of tax in terms of Section 115BBE

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

154 of the Act, while deciding the appeal filed by the\nassessee against the order passed by the Assessing Officer u/s\n143(1)/143(3) of the Act. Therefore, in our considered view, the findings\nor directions given by the learned CIT (A) in Para 6.2.8 for the A.Y 2020-\n21 is beyond the scope of the powers

SPANDANA SPHOORTY FINANCIAL LIMITED,HYDERABAD vs. ACIT., CIRCLE 3(2), HYDERABAD

Accordingly, the addition of Rs.11,44,51,818/- (supra) made by the\nAO, which, thereafter, had been sustained by the CIT(A), is vacated.\nThe Grounds of appeal Nos.3.1 to 3.4 are allowed in terms o...

68\nand 69A are quite similar, we request your good self to analyse the decision and\nappreciate that the same can be applied to our case also. The decision is\nattached for your reference (pls refer from Para 5 on [page 9 till para 15 on page\n9)\niv) Additionally, various appellate forums have held that where books of\naccounts/other