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

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

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

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

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

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

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

68,990/-. 5. Aggrieved by the Final Assessment Order passed by the Assessing Officer, the appellant-company is now in appeal before the Tribunal. 6. The first issue that came-up for consideration through ground nos.1.1 to 1.4 of the assessee’s appeal is addition towards interest on CCDs of Rs.9,06,85,341/-. 7. The facts with regard

ITO, WARD-5(3),, HYDERABAD vs. SHRI KRISHNA KUMAR D SHAH, HUF, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

154 did not apply to the request of the appellant in relation " to adoption of S.R.O. value' as per section 5OC of the Income Tax Act, 1961. (b) The learned CIT(A) incorrectly inferred that the issue relating to adoption of the value as per section 50C was considered in the assessment whereas it was neither raised

ITO, WARD-5(3),, HYDERABAD vs. SHRI BRIJ GOPAL P SHAH, HUF,, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

154 did not apply to the request of the appellant in relation " to adoption of S.R.O. value' as per section 5OC of the Income Tax Act, 1961. (b) The learned CIT(A) incorrectly inferred that the issue relating to adoption of the value as per section 50C was considered in the assessment whereas it was neither raised

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

154,38,00,527/- and (ii) Disallowance of CSR expenses of Rs. 1,42,97,133/- against the returned income of Rs. 50,81,16,931/-. 2.1 Feeling aggrieved, the assessee raised certain objections before the Ld. DRP. The Ld. DRP, after considering the submissions of the assessee and also going through the material available on record, dismissed the objections

SHARE MICROFIN LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2016-17 Share Microfin Ltd Vs. Dy. C. I. T. Hyderabad Circle 3(1) Pan:Aaecs9243C Hyderabad (Appellant) (Respondent) Assessee By: Shri A.G. Sitaraman, Ca Revenue By: Shri Jeevan Lal Lavidiya, Dr Date Of Hearing: 17/04/2023 Date Of Pronouncement: 12/06/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23003.2020 Of The Learned Cit (A)-3, Hyderabad Relating To A.Y.2016-17. 2. There Is A Delay Of 5 Days In Filing Of This Appeal By The Assessee For Which The Assessee Has Filed A Condonation Application Along With An Affidavit Explaining The Reasons For Such Delay. The Reasons Given Therein Is Due To The Prevailing Covid 2019 Pandemic. After Considering The Contents Of The Condonation Application Explaining The Reasons Filed Along With The Affidavit, The Delay In Filing Of The Appeal By The Assessee Is Condoned & The Appeal Is Admitted For Adjudication.

section 41(1). Therefore, the loan waiver cannot be taxed as business profits. 9. Referring to the decision of the Vizag Bench of the Tribunal in the case of ITO vs. Sri Vasavi Polymers (2020) 117 Taxmann.com 236, he submitted that the Tribunal, relying on the decision of the Hon’ble Supreme Court in the case of Mahindra & Mahindra

ACIT., CIRCLE-6(1), HYDERABAD vs. VK WAREHOUSING ENTERPRISES, HYDERABAD

In the result, both the appeals filed by the assessee firm and

154 of the Act before the CIT(A), who vide a separate order dated 28/02/2025, directed the AO to apply the provisions of Section 115BBE only in respect of the addition made under Section 68 of Rs. 25,85,800/- and vacated the application of Section 115BBE in respect of the disallowance

VK WAREHOUSING ENTERPRISES,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

154 of the Act before the CIT(A), who vide a separate order dated 28/02/2025, directed the AO to apply the provisions of Section 115BBE only in respect of the addition made under Section 68 of Rs. 25,85,800/- and vacated the application of Section 115BBE in respect of the disallowance

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

154 of the Act was also passed on 26.02.2021 wherein further interest of Rs.25,27,05,530/- was added in the earlier interest of Rs.42,78,66,807/-, making the total adjustment to Rs.68,05,72,337/-. During the course of appellate proceedings, the appellant submitted that it is not charging interest from non-AEs on delayed receivables due beyond