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

161 taxmann.com 160 (Delhi). 8. The learned CIT-DR, on the other hand, supporting the orders of the LD.CIT(A) submitted that the Explanation - 1 defines the “relevant assessment year”, the assessment year preceding the assessment year relevant to the previous year in which search is conducted or requisition is made which falls beyond six assessment years but not later

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

161 taxmann.com 160 (Delhi). 8. The learned CIT-DR, on the other hand, supporting the orders of the LD.CIT(A) submitted that the Explanation - 1 defines the “relevant assessment year”, the assessment year preceding the assessment year relevant to the previous year in which search is conducted or requisition is made which falls beyond six assessment years but not later

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

In the result, the appeals filed by the assessee for A

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

161 taxmann.com 160 (Delhi). 8. The learned CIT-DR, on the other hand, supporting the orders of the LD.CIT(A) submitted that the Explanation - 1 defines the “relevant assessment year”, the assessment year preceding the assessment year relevant to the previous year in which search is conducted or requisition is made which falls beyond six assessment years but not later

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. SANJAY CHOWDARY GADDIPATI, HYDERABAD

68, in relation to the transfer of\na capital asset, means the full value of the\nconsideration received or accruing as a result of\nthe transfer of the capital asset as reduced by any\nexpenditure incurred wholly and exclusively in\nconnection with such transfer.\n(2) Where the assessee purchases, within the period of 69[two years] after\nthe date

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

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

68,544/- by making addition towards TP adjustment suggested by the learned TPO. 5. Aggrieved, the assessee filed objections before the Hon’ble Dispute Resolution Panel challenging the TP adjustments made by the learned TPO. The Hon’ble DRP, vide its directions issued under Section 144C(5) of the Act dated 11.09.2024, partly allowed the objections of the assessee

MOKAMA MUNGER HIGHWAY LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

68,472) Rs.12,78,47,171/- was disallowed and brought to tax. Page 2 of 25 ITA Nos 1729 2145 and 2146 of 2018 Mokama Munger Highway Ltd Hyderabad. 4. Further, on verification of the P&L A/c, the AO noted that the assessee has debited an amount of Rs.1,11,47,486/- towards provision for major maintenance. On further

MOKAMA MUNGER HIGHWAY LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

68,472) Rs.12,78,47,171/- was disallowed and brought to tax. Page 2 of 25 ITA Nos 1729 2145 and 2146 of 2018 Mokama Munger Highway Ltd Hyderabad. 4. Further, on verification of the P&L A/c, the AO noted that the assessee has debited an amount of Rs.1,11,47,486/- towards provision for major maintenance. On further

MOKAMA MUNGER HIGHWAY LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-16(4), HYDERABAD

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

68,472) Rs.12,78,47,171/- was disallowed and brought to tax. Page 2 of 25 ITA Nos 1729 2145 and 2146 of 2018 Mokama Munger Highway Ltd Hyderabad. 4. Further, on verification of the P&L A/c, the AO noted that the assessee has debited an amount of Rs.1,11,47,486/- towards provision for major maintenance. On further

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. M/S. MUSADDILAL GEMS AND JEWELS PRIVATE LIMITED, HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

section 68 of the Act. Further, it was the contention of the ld. DR that the assessee had utilized the said amount of Rs. 40 crores for purchasing the Gold from Ashtalaxmi Gold and Impex Gold. It was submitted that the reliance of the ld.CIT(A) on the statement of Mr. Neel Sunder recorded by the police during

VAISHNAVI BULLION PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

section 68 of the Act. Further, it was the contention of the ld. DR that the assessee had utilized the said amount of Rs. 40 crores for purchasing the Gold from Ashtalaxmi Gold and Impex Gold. It was submitted that the reliance of the ld.CIT(A) on the statement of Mr. Neel Sunder recorded by the police during

MUSADDILAL GEMS JEWELS PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

section 68 of the Act. Further, it was the contention of the ld. DR that the assessee had utilized the said amount of Rs. 40 crores for purchasing the Gold from Ashtalaxmi Gold and Impex Gold. It was submitted that the reliance of the ld.CIT(A) on the statement of Mr. Neel Sunder recorded by the police during

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. VAISHNAVI BULLION PRIVATE LIMITED, HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

section 68 of the Act. Further, it was the contention of the ld. DR that the assessee had utilized the said amount of Rs. 40 crores for purchasing the Gold from Ashtalaxmi Gold and Impex Gold. It was submitted that the reliance of the ld.CIT(A) on the statement of Mr. Neel Sunder recorded by the police during

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

The appeal of the Assessee is allowed on this ground alone

161. [This Court observed that the "legal fiction undoubtedly is to be construed in such a manner so as to enable a person, for whose benefit such legal fiction has been created, to obtain all consequences flowing therefrom."] 110. The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped the clock of limitation

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

68,545 to the international transactions pertaining to purchase of raw materials/finished goods and sale of finished goods and INR 8,13,72,292 towards payment of royalty by the Appellant to its Associated Enterprises ('AEs'). On the facts and in the circumstances of the case and in law, the Ld. AO / Ld. TPO / Hon'ble Panel erred

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

161. [This Court observed that the "legal fiction undoubtedly is to be construed in such a manner so as to enable a person, for whose benefit such legal fiction has been created, to obtain all consequences flowing therefrom."] 110. The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped the clock of limitation

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

AGARWAL INDUSTRIES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

161 (SC) Officer was justified in passing assessment order making additions under section 68 for share capital / premium received by assessee company A. (1958) 34 ITR 68 Section 68 casts liability on Govindrarajulu 807 SC assessee: The assessee has to Mudaliar prove satisfactorily the source and nature of certain amounts of cash received during the accounting year