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

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

In the result, appeal of the Assessee for the\n

68,62,731 towards interest on outstanding receivables.\n2. On the facts and in the circumstances of the case and in law, the\nLd. TPO erred and the Hon'ble DRP further erred in\nupholding/confirming the action of the Ld. TPO, in rejecting the\ntransfer pricing analysis/study prepared by the Appellant and\nconducting fresh benchmarking, without appreciating that none

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

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

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

DCIT, EXEMPTIONS CIRCLE, HYDERABAD vs. HYDERABAD METROPOLITAN DEVELOPMENT AUTHORITY, SECUNDERABAD

In the result, both the appeals of assessee and Revenue are allowed for statistical purposes

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68,19,961/- is a part and parcel of the assessee authority besides the fact that the assessee is in receipt of the same. 8) CIT(A) erred in not considering the fact that there is no such provision / scope in the bye-laws of the assessee to facilitate the policies of the government; whether they are chartable

HYDERABAD METROPOLITAN DEVELOPMENT AUTHORITY,HYDERABAD vs. DCIT, EXEMPTIONS CIRCLE-1(1), HYDERABAD

In the result, both the appeals of assessee and Revenue are allowed for statistical purposes

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68,19,961/- is a part and parcel of the assessee authority besides the fact that the assessee is in receipt of the same. 8) CIT(A) erred in not considering the fact that there is no such provision / scope in the bye-laws of the assessee to facilitate the policies of the government; whether they are chartable

LAKSHMIRAMANA BANDARU,KADAPA vs. ITO., WARD-1, KADAPA

Bench: Us:

254 of the Income-tax Act, 1961 (for short, “the Act”), dated 30.04.2021. The assessee has assailed the impugned order on the following grounds of appeal before us: “1). The addition of Rs. 40,61,283/- to the returned income is incorrect and not justified when the appellant has proved the sources and explained the same to the assessing officer

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

DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD vs. BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU, YSR DIST., YSR DIST.

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

section 68 of the Act ignoring the original remand report dated 17/3/2015. 2) The Ld. CIT (A) has erred in upholding the order of the ld.AO who had made addition of Rs. 15,99,60,041/- on account of notional gain arising out of the foreign exchange fluctuation relying on the decision of the Hon’ble Apex Court

BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU,KADAPA vs. DCIT, CIRCLE-1(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

section 68 of the Act ignoring the original remand report dated 17/3/2015. 2) The Ld. CIT (A) has erred in upholding the order of the ld.AO who had made addition of Rs. 15,99,60,041/- on account of notional gain arising out of the foreign exchange fluctuation relying on the decision of the Hon’ble Apex Court

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

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

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

section is very clear and the appellant has incurred the expenditure and the appellant has made the payment to the various parties and persons. The appellant has, to circumvent, not accounted for the same and has also not brought out any evidence from M/s.DLF that they have accounted for such transactions in their books as cash payments

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

254(2) when it was pointed out to the Tribunal that the judgment of the co-ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material, which was already on record. The Tribunal has acknowledged its mistake; it has accordingly rectified its order

NCC LIMITED, ,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(1),, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

254(2) when it was pointed out to the Tribunal that the judgment of the co-ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material, which was already on record. The Tribunal has acknowledged its mistake; it has accordingly rectified its order

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

254(2) when it was pointed out to the Tribunal that the judgment of the co-ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material, which was already on record. The Tribunal has acknowledged its mistake; it has accordingly rectified its order

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

254(2) when it was pointed out to the Tribunal that the judgment of the co-ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material, which was already on record. The Tribunal has acknowledged its mistake; it has accordingly rectified its order

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

254(2) when it was pointed out to the Tribunal that the judgment of the co-ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material, which was already on record. The Tribunal has acknowledged its mistake; it has accordingly rectified its order

NCC LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

254(2) when it was pointed out to the Tribunal that the judgment of the co-ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material, which was already on record. The Tribunal has acknowledged its mistake; it has accordingly rectified its order

NCC LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

254(2) when it was pointed out to the Tribunal that the judgment of the co-ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material, which was already on record. The Tribunal has acknowledged its mistake; it has accordingly rectified its order

ANDHRA PRADESH ADVOCATES WELFARE FUND,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(2), HYDERABAD,

In the result, all the three appeals of the assessee are dismissed

Bench: SHRI K.NARASIMHA CHARY (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

254 to be applied. 63. We, therefore, hold that the doctrine of repugnance does not apply when a Central Act contains a clause that excludes its application where State legislation exists on the same subject. This clause demonstrates a clear legislative intent to defer to State law, effectively resolving potential conflicts and making the invocation of the doctrine of repugnance

ANDHRA PRADESH ADVOCATES WELFARE FUND,HYDERABAD vs. INCOME TAX OFFICER, WARD 8(2), HYDERABAD, HYDERABAD

In the result, all the three appeals of the assessee are dismissed

Bench: SHRI K.NARASIMHA CHARY (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

254 to be applied. 63. We, therefore, hold that the doctrine of repugnance does not apply when a Central Act contains a clause that excludes its application where State legislation exists on the same subject. This clause demonstrates a clear legislative intent to defer to State law, effectively resolving potential conflicts and making the invocation of the doctrine of repugnance