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

GANGADHAR AGARWAL,NIZAMABAD vs. ITO., WARD-1, NIZAMABAD

68, 69, 69A, 69B, 69C and 69D. The same was\namended by the 2nd Amendment Act; w.e.f. 01.04.2017, enhancing the rate to 60%. Hence there\nwas no new liability created and the rate of tax merely stood enhanced which is applicable to the\nassessments carried on in that year. The enhanced rate applies from the commencement of the\n assessment

SUBHASH KUMAR KEDIA,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.707/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Subhash Kumar Kedia Vs. Asstt. C. I. T. Hyderabad Central Circle 3(1) Pan:Afvpk8915Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No. 405/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Vs. Shri Bikash Kumar Asstt. C. I. T. Kedia Hyderabad Central Circle 3(1) Pan:Afapk8794E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Vamshi Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 29/10/2024 आदेश/Order Per Manjunatha, G. A.M These Two Appeals Filed By Different Assessees Are Directed Against The Separate, But Identical Orders Dated 31/01/2020 Of The Learned Cit (A)-11, Hyderabad Relating To Page 1 Of 33

Section 260-A of the Act, 1961.” 16. Similar view has been taken by the Hon'ble Supreme Court in the case of CIT (Central) vs. Sunita Dhadda in Special Leave Petition (Civil) Nos.9432/2018 dated 28/03/2018 wherein the Hon'ble Supreme Court has upheld the order of the Hon'ble Rajasthan High Court. 17. Coming back to the case

BIKASH KUMAR KEDIA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.707/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Subhash Kumar Kedia Vs. Asstt. C. I. T. Hyderabad Central Circle 3(1) Pan:Afvpk8915Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No. 405/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Vs. Shri Bikash Kumar Asstt. C. I. T. Kedia Hyderabad Central Circle 3(1) Pan:Afapk8794E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Vamshi Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 29/10/2024 आदेश/Order Per Manjunatha, G. A.M These Two Appeals Filed By Different Assessees Are Directed Against The Separate, But Identical Orders Dated 31/01/2020 Of The Learned Cit (A)-11, Hyderabad Relating To Page 1 Of 33

Section 260-A of the Act, 1961.” 16. Similar view has been taken by the Hon'ble Supreme Court in the case of CIT (Central) vs. Sunita Dhadda in Special Leave Petition (Civil) Nos.9432/2018 dated 28/03/2018 wherein the Hon'ble Supreme Court has upheld the order of the Hon'ble Rajasthan High Court. 17. Coming back to the case

P CHADRA SEKHAR REDDY,NELLORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, TIRUPATHI

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.16/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Shri P Chandra Sekhar Vs. Acit Reddy Central Circle Nellore Tirupati Pan:Aitpp3592M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca M.V. Prasad राज" व "ारा/Revenue By:: Shri Ranjan Agrawala, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Pronouncement: 26/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri P Chandra Sekhar Reddy (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) Dated 08.11.2023 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Learned Cit (Appeals) Is Erred In Facts & Law While Passing The Order.

260/- and agricultural income of Rs.2,82,720/-. The case of the assessee was selected for scrutiny and notice under section 143(2) of the Act was issued on 04.07.2018. After considering the submissions of the assessee, the Ld. AO completed assessment under section 143(3) r.w.s. 153A of the Act on 09.04.2019, making the following additions

ISHOO NARANG,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.450/Hyd/2022 & S.A. No.1/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Ishoo Narang Vs. Dy. Cit Hyderabad Circle 2(1) Pan:Aaupn9082B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Smt. Th Vijaya Lakshmi, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/08/2024 घोषणा की तारीख/Pronouncement: 25/09/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 15/07/2022 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2014-15. 2. The Assessee Has Raised The Following Grounds: “1. The Ld. Cit(A) Erred In Dismissing The Appeal. 2. The Ld.Cit(A) Erred In Holding That Al The Mandatory Preconditions Before Reopening Of Assessment U/S 147 Of The Act Were Duly Complied & Met With By The A.O.

Section 260-A of the Act, 1961.” 16. Similar view has been taken by the Hon'ble Supreme Court in the case of CIT (Central) vs. Sunita Dhadda in Special Leave Petition (Civil) Nos.9432/2018 dated 28/03/2018 wherein the Hon'ble Supreme Court has upheld the order of the Hon'ble Rajasthan High Court. 17. Coming back to the case

JAYA DIAGNOSTIC & RESEARCH CENTRE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 Jaya Diagnostic & Vs. Dy. C.I.T. Circle 2(2) Research Centre Ltd, Hyderabad Hyderabad Pan:Aacj5137J (Appellant) (Respondent) Assessee By: Shri Pawan Kumar Chakrapani Revenue By: Shri Kumar Aditya, Dr Date Of Hearing: 19/09/2022 Date Of Pronouncement: 17/10/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 27Th October, 2017 Of The Learned Cit (A)-2, Hyderabad Relating To A.Y.2014-15. 2. There Is A Delay Of 7 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. After Considering The Contents Of The Condonation Application Filed Along With The Affidavit Explaining The Reasons For Such Delay & After Hearing The Learned Dr, The Delay In Filing Of This Appeal By The Assessee Is Condoned & The Appeal Is Admitted For Adjudication. Page 1 Of 13

Section 68 would be squarely applicable to the appellant. AS regards the contention of the AR that since scrutiny assessment of Mr. Bharat has been completed without making addition, the protective addition made in the appeal under consideration has no legs to stand misplaced and misconceived. Completion of assessment u/s. 143(3) does not grant a stamp of genuineness/authenticity

SRINIVAS CHOWDARY VALLABANENI,SECUNDERAB vs. DCIT., CENTRAL CIRCLE -1(4), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1462/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Shri Srinivas Chowdary Vs. Dy.Cit Vallabaneni, Secunderabad Central Circle 1(4) Pan:Aeipv3757R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Phaneendra Nag, Ca राज" व "ारा/Revenue By:: Shri Ranjan Agrawala, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Pronouncement: 26/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

260/-, which included Rs.35 lakhs offered by the Page 2 of 8 IT No 1462 of 2025 Srinivas Chowdary Vallabaneni assessee as additional income during the course of the search proceedings. The case of the assessee was selected for scrutiny and accordingly notices under sections 143(2) and 142(1) of the Act were issued by the Learned Assessing

DCIT., CIRCLE-2(1), HYDRABAD vs. KALPTARU INVESTMENTS PRIVATE LIMITED, HYDERABAD

In the result, appeal ITA

260/- on account of disallowance under\nsection 14A of the Income Tax Act.\n2.\nIn this case, information has been received under Project Falcon from\nDGIT(Investigation), Mumbai on 06.03.2020 through the Income-tax Business\nApplication regarding coordinated and premediated trading on the Bombay Stock\nExchange by engaging in reversal trades in illiquid stock options resulting in non-\ngenuine business

MAHENDER REDDY GANJI,WARANGAL vs. INCOME TAX OFFICER, WARD-1, WARANGAL

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

Bench: Shri Laliet Kumarassessment Year: 2016-17 Mahender Reddy Ganji, Vs. The Income Tax Officer, House No.1-600/4, Near Ward – 1, Petrol Pump, Upparapalle, Warangal, Kesamudram, Warangal, Hanamkonda. Telangana. Pan : Bglpg6211P. (Appellant) (Respondent) Assessee By: Shri Pradeep Raj Kuna, C.A. Revenue By: Shri Mookambikeyan, Sr.Ar Date Of Hearing: 02.04.2024 Date Of Pronouncement: 02.04.2024

68,260/- and Discount of Rs.42,921/-.The net profit and Total Income has been reported at Rs.2,38,258/-. The return has been filed reporting total income at Rs.2,38,260/-. Accordingly, the income was reported at 1.18 % of gross turnover which was very low considering nature of business of the assessee. Further, complete details of claim of Purchases

SRINIVAS SHAH RADRARAJU ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.957/Hyd/2019 (निर्धारण वर्ा/Assessment Year: 2014-15) Srinivas Shah Rudraraju Vs. Dcit, Circle-2(1) Hyderabad Hyderabad [Pan :Afcpr1979L] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 15/01/2025 घोर्णध की तधरीख/Date Of 05/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)]-2, Guntur, Pertaining To A.Y.2014-15. 2. The Brief Facts Of The Case Are That, The Assessee Is An Individual, Filed His Return Of Income For The A.Y.2014-15 On 31.03.2015, Admitting Total Income Of Rs.53,50,976/-. The Case Was Selected For Scrutiny Under Cass For The Reason ‘Suspicious Long Term Capital Gain On Shares’ & During The Course Of Assessment Proceedings, The Assessing Officer, Noticed That The 2 Srinivas Shah Rudra Raju

Section 260-A of the Act, 1961.” 16. Similar view has been taken by the Hon'ble Supreme Court in the case of CIT (Central) vs. Sunita Dhadda in Special Leave Petition (Civil) Nos.9432/2018 dated 28/03/2018 wherein the Hon'ble Supreme Court has upheld the order of the Hon'ble Rajasthan High Court. 17. Coming back to the case

DY COMMISSIONER OF INCOME TAX ,CIRCLE -8(1) , HYDERABAD vs. THIRUPALAPPA CHOWDARY NAGELI, HYDERABAD

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

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2016-17 Dy. C.I.T. Vs. Shri Thirupalappa Circle 8(1) Chowdary Nageli, Hyderabad Hyderabad Pan:Adbpn9171H (Appellant) (Respondent) Assessee By: Shri Mohammed Afzal, Advocate Revenue By: Shri Kumar Aditya, Cit (Dr) Date Of Hearing: 18/08/2022 Date Of Pronouncement: 23/08/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.09.2020 Of The Learned Cit (A)-8, Hyderabad Relating To A.Y.2016-17. 2. Grounds Of Appeal 1 & 2 Raised By The Revenue Are As Under: “1. The Learned Cit (A) Erred In Deleting The Addition U/ 68 Of Rs.40,50,000/- Under The Fact & Circumstances Of The Case. 2. The Learned Cit (A) Failed To Appreciate That The Assessee Failed To Establish With Documentary Evidences That The Rental Receipts Received In Puttaparthi Were Deposited In Cash In Hyderabad Which Is Far Of Place”.

68 of Rs.40,50,000/- under the fact and circumstances of the case. 2. The learned CIT (A) failed to appreciate that the assessee failed to establish with documentary evidences that the rental receipts received in Puttaparthi were deposited in cash in Hyderabad which is far of place”. Page 1 of 13 ITA No 779 of 2020 Thirupalappa Chowdary Nageli

ACIT, CIRCLE-2(1), HYDERABAD vs. Y S JAGAN MOHAN REDDY, KADAPA

In the result, cross objection filed by the assessee is\nallowed

68,666/-. On this amount, tax works\nout to Rs.6,86,42,561/- and the same has been rounded off to\nRs.6.87 crores. As this cost has been met out of sale proceeds,\nthe cash in hand after meeting tax liability would be Rs.139.67\ncr., which apparently rounded off to Rs.139 cr. and the same has\nbeen paid to assessee

HARSCO INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT-8(1), HYDERABAD

In the result, appeal of the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 92B Explanation (c) inserted vide Finance Act 2012 as applicable with retrospective effect from 1/4/2002. Hon'ble Madras high court's recent judgment in PCIT Vs Reddington India dated 10/12/2020 in Tax Appeals 590-591/2019 also holds the same view. We thus, accept the Revenue's arguments in principle that interest on receivables is indeed an international

HEXAGON CAPABILITY CENTER INDIA PRIVATE ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 92B Explanation (c) inserted vide Finance Act 2012 as applicable with retrospective effect from 1/4/2002. Hon'ble Madras high court's recent judgment in PCIT Vs Reddington India dated 10/12/2020 in Tax Appeals 590-591/2019 also holds the same view. We thus, accept the Revenue's arguments in principle that interest on receivables is indeed an international

IVY COMPTECH PRIVATE LIMITED,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuay : 2013-14 Ivy Comptech Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1) Hyderabad. Pan – Aaaci 8884K (Appellant) (Respondent) Assessee By: Shri Prashant Meharchandani Revenue By: Shri R. Dipak Date Of Hearing: 27/04/2021 Date Of Pronouncement: 20/07/2021

260/- and further delete similar adjustments of Rs.12,12,62,138/- and Rs.12,71,68,334/- in assessee's appeals ITA No.131 & 2196/H/2017 in AYs 2012-13 and 2013-14 (supra); respectively. :- 24 -: IVY Comptech Pvt. Ltd., Hyd. 8.1 As the issue in the case under consideration is similar, as stated in the facts of the case on hand

ACIT., CIRCLE-5(1), HYDERABAD vs. PRAGNAPUR DEVELOPERS PRIVATE LIMITED, HYDERABAD

Accordingly, the grounds Nos. 1 to 12 are partly allowed

Bench: Us:

section 144B of the Act, dated 21-03-2024, recomputed the total income of the assessee company at Rs. 21,68,99,368/-. 9. Aggrieved, the assessee company carried the matter in appeal before the CIT(A). The assessee company in the course of the appellate proceedings assailed the disallowance of its claim for deduction of “cost of improvement

ALLCARGO GATI LIMITED(FORMALLY KNOWN AS GATI LIMITED),HYDERABAD vs. ITO, WARD-2(2), HYD, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

68,19,473 towards amounts utilized for construction of buildings is erroneous. 7. The appellant contends that out of sum of Rs.11.94,06,472 the amount utilized for construction of buildings was Rs.8,57,41,868, amount utilized for furniture and fixtures was Rs.82,05,480, amount utilized for office equipments was Rs.42,59,783, and amount utilized for Plant