SPECTRA EQUIPMENT PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD 3(1),, HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2017-18 Spectra Equipment Private Vs. The Income Tax Officer, Ward 3(1), Limited, Hyderabad. Hyderabad. Pan No.Aaccs8677C. (Appellant) (Respondent) Assessee By: Ms. Akanksha, C.A. For Shri Sunil Kumar Jain, C.A. Revenue By: Ms. Narmada, Cit-Dr For Shri Madan Mohan Meena, Sr.D.R. Date Of Hearing: 11.12.2024 Date Of Pronouncement: 18.12.2024

193, 194, 194A, 194B, 194BB and 194D, the rate or rates of income-tax specified in this behalf in the Finance Act of the relevant year ; (iii) for the purposes of deduction of tax under section 194LBA or section 194LBB or section 194LBC or section 195, the rate or rates of income-tax specified in this

YADAGIRI GURRAM,NALGONDA vs. INCOME TAX OFFICER, WARD-1, NALGONDA

In the result, the appeal of the assessee is allowed for

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaआ.अपी. सं / Ita No.1214/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2017-18) Shri Yadagiri Gurram Nalgonda Pan:Bdrpg9128G (Appellant) Vs. Income Tax Officer Ward 1 Nalgonda (Respondent) निर्धारिती द्वारा / Assessee By: Adv. Dayakar राजस्व द्वारा / Revenue By: Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख / Date Of Hearing: 05/01/2026 घोषणा की तारीख / Pronouncement: 09/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Yadagiri Gurram, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 30.05.2025 For The A.Y 2017-18.

section 144 of the Act vide order dated 06.12.2019, assessing the total income of the assessee at Rs.21,77,257/-. 4. Aggrieved with the order of the Ld. AO, the assessee preferred an appeal before the Ld. CIT(A). The Ld. CIT(A), on verification of the bank statements, found that the actual cash deposits in the bank accounts

INCOME TAX OFFICER, WARD-1, KADAPA vs. PRITHAM & PRATHIK HOSPITALS PRIVATE LIMITED , KADAPA

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 Income Tax Officer, Vs. M/S. Pritham & Prathik Ward – 1, Hospitals Pvt. Limited, Kadapa. Kadapa – 516002. Pan : Aahcp6013E. (Appellant) (Respondent) C.O.No.10/Hyd/2019 (In Ita 97/Hyd/2019) M/S. Pritham & Prathik Vs. Income Tax Officer, Hospitals Pvt. Limited, Ward – 1, Kadapa – 516002. Kadapa. Pan : Aahcp6013E. (Cross Objector / (Respondent) Appellant) Assessee By: Ms. S. Sandhya, Advocate. Revenue By: Ms. Swapna. Date Of Hearing: 24.11.2022 Date Of Pronouncement: 29.11.2022 Per Laliet Kumar, J.M. This Appeal By The Revenue & Cross-Objection By The Assessee Are Directed Against The Order Of Commissioner Of Income Tax (Appeals), Kurnool Dated 29.11.2018 For The Assessment Year 2014-15. 2. The Revenue Has Raised The Following Grounds :

Section 68 of the Income Tax Act, 1961. There are plethora of decisions consequent to the decision of Lovely Exports. It is also well settled law that onus of proving credits in its book of accounts lies squarely on the assessee and such proof consists of proving the identity of the subscriber or creditor, capacity of such creditor

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

Section 147. In :16: ITA Nos. 1717 to 1720/Hyd/2017 & this regard, he relied upon the following judicial precedents :  DCIT Vs. Eversmile Construction Co. (P.) Ltd. [2012] 143 TTJ 322 (Mumbai)  KNR Constructions Vs. DIT IT Appeal Nos.946 to 948 and 983 to 986/Hyd/2015, dated 16-102015  Malpani Estates Vs. Asst. CIT [2014] 64SOT 105 (Pune)  Goodyear India

BHARAT FINANCIAL INCLUSION LIMITED ,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result, appeal of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahuassessment Year: 2014-15 Bharat Financial Inclusion Vs. Dy. Commissioner Of Ltd., Hyderabad. Income-Tax, Circle – 1(2), Hyderabad. Pan-Aaics2940J (Appellant) (Respondent) Assessment Year: 2012-13 Dy. Commissioner Of Vs. Bharat Financial Inclusion Income-Tax, Ltd., Hyderabad. Circle – 1(2), Hyderabad Pan-Aaics2940J (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri Sunil Kumar Pandey Date Of Hearing: 22/02/2021 Date Of Pronouncement: 20/04/2021

193/- u/s 43B by holding that the same had not been paid before the due date. 7.1 The CIT(A) after considering the submissions of the assessee, allowed this ground by observing as under: “The submissions brought out supra were perused. It is seen from the judicial decisions and the decisions of the Tribunal that the provisions made for contribution

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. BHARAT FINANCIAL INCLUSION LIMITED(FORMERLY SKS MICROFINANCE LIMITED), HYDERABAD

In the result, appeal of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahuassessment Year: 2014-15 Bharat Financial Inclusion Vs. Dy. Commissioner Of Ltd., Hyderabad. Income-Tax, Circle – 1(2), Hyderabad. Pan-Aaics2940J (Appellant) (Respondent) Assessment Year: 2012-13 Dy. Commissioner Of Vs. Bharat Financial Inclusion Income-Tax, Ltd., Hyderabad. Circle – 1(2), Hyderabad Pan-Aaics2940J (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri Sunil Kumar Pandey Date Of Hearing: 22/02/2021 Date Of Pronouncement: 20/04/2021

193/- u/s 43B by holding that the same had not been paid before the due date. 7.1 The CIT(A) after considering the submissions of the assessee, allowed this ground by observing as under: “The submissions brought out supra were perused. It is seen from the judicial decisions and the decisions of the Tribunal that the provisions made for contribution

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

193/- against brought\nforward losses of Rs.4,74,89,404/-. The return of income of the assessee was\nselected for scrutiny and the Learned Assessing Officer (“Ld. AO”) passed an\norder under section 143(3) of the Income Tax Act, 961 (“the Act\") on\n29.03.2004, making total disallowances of Rs.3,15,87,481/- on account of\nbusiness expenditure

ORBIT 9 ELECTRONICS ,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(2) , HYDERABAD

In the result, appeal of the assessee is allowed in part

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charym/S.Orbit 9 Electronics, Vs. The Income Tax Officer, Hyderabad Ward-6(2), [Pan No. Aabfo6265A] Hyderabad

Section 44ADA of the Act inasmuch as the gross business receipts of the assessee exceed the threshold limit of Rs.50 lakhs. Nextly, as a matter of fact, on verification of record, Ld. CIT(A) found that this amount of Rs.1,29,07,148/- which was received from the clients/customers and in respect of which, TDS was deducted

ITO, WARD-1, KURNOOL, KURNOOL vs. S.V. MOHAN REDDY, KURNOOL, KURNOOL

In the result, appeal of the revenue is dismissed

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

68 of the l.T. Act, 1961 are to be treated as the business receipts of agricultural commodities with out any evidence of purchase bills of the same and more so when these receipts are not even disclosed in the Return of Income filed by the assessee and taken this, after thought stand at the time of assessment to explain

ADIT(IT)-I,, HYDERABAD vs. M/S KAMINENI HOSPITALS PRIVATE LIMITED,, HYDERABAD

In the result, appeal of the Revenue is allowed for statistical purposes as indicated herein above

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2012-13 Deputy Commissioner Of Vs. M/S. Kamineni Hospitals Income Tax-1, (International Pvt Ltd., Transaction), L.B. Nagar, Hyderabad. Hyderabad. Pan: Aaack 8356 J (Appellant) (Respondent) Assessee By: Sri A. Srinivas Revenue By: Sri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 31/01/2020 Date Of Pronouncement: 25/06/2020

68, Mansoorabac Village, Saroor nagar Mandal, Ranga Reddy District vide Sale Deed dated 16/12/2011 registered as Doc. No. 5079/2011 for total sale consideration of Rs. 24,20,00,000. The sale deed was executed by 8 persons in favour of the assessee viz., Smt. K. Urmila Reddy, Sri K. Prabhakar Reddy, Smt. K. Sarita Reddy, Smt. K. Vijita Reddy

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

193 ITR 321 (SC). 32. The Ld. AR further submitted that the TPO had grossly erred in law and on facts of the case by wrongly observing that the assessee company had failed to submit the audited financial statements and also the copies of “Form 10CCB” for each of the chilling units, i.e., eligible units. The Ld. AR had drawn

ORCHASP LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-1(2) , HYDERABAD

In the result, the Tax Case Appeals are dismissed and the substantial questions of law are answered against the Revenue

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2011-12 Orchasp Limited Vs. Dy. Cit Hyderabad Circle 1(2) Pan:Aabcc4776F Hyderabad (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao, Ca Revenue By: Shri B. Yadagiri, Dr Date Of Hearing: 13/04/2023 Date Of Pronouncement: 20/04/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23/03/2022 Of The Learned Cit (A)- Nfac, Relating To A.Y. 2011-12. 2. The Grounds Raised By The Assessee Are As Under: “1. On The Facts & In The Circumstances Of The Case The Appellate Order Passed By The Cit(A) Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant. 2. The Cit(A) Ought To Have Appreciated The Fact That The Amount Of Investment Made Is Completely In Wholly Owned Subsidiary Company Which Is Revenue In Nature & Not A Capital Expenditure. 3. The Ld. Cit(A) Ought To Have Accepted The Investments Written Off Of Rs.3,60,72,141/- Since The Said Amount Was Not Received From The Third Party To The Subsidiary & Thus, The Same Amount Was Written Off By The Virtue Of The Circular No. 69 Dt. 27-07-2011 Issued By Rbi.

68 to 73 of the Paper Book, he drew the attention of the Bench to the High Court order dated 15.4.2010 for winding up. Referring to page 74 of the Paper Book, he drew the attention of the Bench to the statement showing the receivables from wholly owned subsidiary, amount capitalized and investments written off in each year from financial

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

193/- in respect of notional interest on delayed receipt of trade receivables from Associated Enterprises. 7. The Learned DRP/AO/TPO ought to have appreciated that trade receivables arise in the normal course of business and are not to be treated as unsecured loans for the levy of interest. 8. The Learned DRP/AO/TPO ought to have appreciated that the Assessee

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

68,345 Ciment Francais SA Software Lincense fees paid 48,89,635 CTG SpA Consultancy service fee paid 4,47,17,617 CTG SpA Consultancy service fee paid 5,28,26,169 (CWIP) Itlacementi Fabbriche IT services 2,35,51,829 Riunite Cemento SpA Zuari Cement Limited, Kadapa Itlacementi Fabbriche Reimbursement of expenses paid 6,95,167 Riunite Cemento

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

68,345 Ciment Francais SA Software Lincense fees paid 48,89,635 CTG SpA Consultancy service fee paid 4,47,17,617 CTG SpA Consultancy service fee paid 5,28,26,169 (CWIP) Itlacementi Fabbriche IT services 2,35,51,829 Riunite Cemento SpA Zuari Cement Limited, Kadapa Itlacementi Fabbriche Reimbursement of expenses paid 6,95,167 Riunite Cemento

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

68,345 Ciment Francais SA Software Lincense fees paid 48,89,635 CTG SpA Consultancy service fee paid 4,47,17,617 CTG SpA Consultancy service fee paid 5,28,26,169 (CWIP) Itlacementi Fabbriche IT services 2,35,51,829 Riunite Cemento SpA Zuari Cement Limited, Kadapa Itlacementi Fabbriche Reimbursement of expenses paid 6,95,167 Riunite Cemento

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

68,345 Ciment Francais SA Software Lincense fees paid 48,89,635 CTG SpA Consultancy service fee paid 4,47,17,617 CTG SpA Consultancy service fee paid 5,28,26,169 (CWIP) Itlacementi Fabbriche IT services 2,35,51,829 Riunite Cemento SpA Zuari Cement Limited, Kadapa Itlacementi Fabbriche Reimbursement of expenses paid 6,95,167 Riunite Cemento

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

68,345 Ciment Francais SA Software Lincense fees paid 48,89,635 CTG SpA Consultancy service fee paid 4,47,17,617 CTG SpA Consultancy service fee paid 5,28,26,169 (CWIP) Itlacementi Fabbriche IT services 2,35,51,829 Riunite Cemento SpA Zuari Cement Limited, Kadapa Itlacementi Fabbriche Reimbursement of expenses paid 6,95,167 Riunite Cemento

DCIT., CIRCLE 8(1), HYDERABAD vs. EAST INDIA PETROLEUM LIMITED, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.1087/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19) Deputy Commissioner Of Vs. East India Petroleum Income Tax Limited Circle-8(1)(Incharge) Hyderabad Hyderabad [Pan : Aaace4494K] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri H.Srinivasulu, Ar रधजस् व द्वधरध/Revenue By: Ms.M.Narmada, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 16/01/2025 घोर्णध की तधरीख/Date Of 06/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Revenue Is Directed Against Order Dated 19.08.2024 Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre (Nfac), Delhi, Pertaining To A.Y.2018-19. 2. The Brief Facts Of The Case Are That The Assessee, Engaged In The Business Of Providing Terminalling Services To Oil Marketing Companies For Storage Of Bulk Liquid Products Including Fuels Like High Speed Diesel, Motor Spirit, Petroleum

68,28,250/-. On amalgamation, the same loan liability has been taken over by the assessee and the assessee company has treated interest as revenue expenditure. Therefore, observed that, if this claim of interest expenditure is allowed, it would amount to allowing assessee company payment of interest on money borrowed for buying its own share capital. Therefore, called upon