NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

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

1. The impugned order of the learned Authorities below in so far as it is against the appellant is opposed to law, weight of evidence, natural justice, probabilities, facts and circumstances of the Appellant's case. 2. The Appellant denies himself liable to be assessed on a total income of Rs.30,60,57,930/-, as against the income returned

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

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

1. The impugned order of the learned Authorities below in so far as it is against the appellant is opposed to law, weight of evidence, natural justice, probabilities, facts and circumstances of the Appellant's case. 2. The Appellant denies himself liable to be assessed on a total income of Rs.30,60,57,930/-, as against the income returned

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

1. On the facts and circumstances of the case and in law, the Ld. Gen CIT(A) erred in dismissing the appeal and enhancing the income of Rs. 39,48,50,000/- towards unexplained money u/s 69A of the IT Act, 1961. 2. On the facts and circumstances of the case and in law, the enhancement of income

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

1. On the facts and circumstances of the case and in law, the Ld. Gen CIT(A) erred in dismissing the appeal and enhancing the income of Rs. 39,48,50,000/- towards unexplained money u/s 69A of the IT Act, 1961. 2. On the facts and circumstances of the case and in law, the enhancement of income

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

1. On the facts and circumstances of the case and in law, the Ld. Gen CIT(A) erred in dismissing the appeal and enhancing the income of Rs. 39,48,50,000/- towards unexplained money u/s 69A of the IT Act, 1961. 2. On the facts and circumstances of the case and in law, the enhancement of income

UNION BANK OF INDIA,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

263/- and then computed 20% net profit of Rs.3,18,94,43,853/-. The Ld. CIT (A) after considering revised computation filed by the assessee, has deleted the addition made by the Assessing Officer towards reserve created for eligible profit u/s 36(1)(viii) of the Act. 8. The Ld. DR submitted that the Ld. CIT (A) is erred

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD vs. ANDHRA BANK , HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

263/- and then computed 20% net profit of Rs.3,18,94,43,853/-. The Ld. CIT (A) after considering revised computation filed by the assessee, has deleted the addition made by the Assessing Officer towards reserve created for eligible profit u/s 36(1)(viii) of the Act. 8. The Ld. DR submitted that the Ld. CIT (A) is erred

UNION BANK OF INDIA (ERSTWHILE- ANDHRA BANK),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

263/- and then computed 20% net profit of Rs.3,18,94,43,853/-. The Ld. CIT (A) after considering revised computation filed by the assessee, has deleted the addition made by the Assessing Officer towards reserve created for eligible profit u/s 36(1)(viii) of the Act. 8. The Ld. DR submitted that the Ld. CIT (A) is erred

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD vs. ANDHRA BANK , HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

263/- and then computed 20% net profit of Rs.3,18,94,43,853/-. The Ld. CIT (A) after considering revised computation filed by the assessee, has deleted the addition made by the Assessing Officer towards reserve created for eligible profit u/s 36(1)(viii) of the Act. 8. The Ld. DR submitted that the Ld. CIT (A) is erred

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

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. MYLAN LABORATORIES LIMITED , HYDERABAD

In the result, appeal of the assessee is partly allowed

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

68 of the Act for want of proof. 19. Having regard to the rival contentions and material on record. We find that u/s 251(1) of the Act, the CIT(A) has the power to confirm, reduce, enhance or annul the assessment in an appeal against an order of assessment. The Hon’ble Supreme Court in the case of Shapoorji

MYLAN LABORATORIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

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

68 of the Act for want of proof. 19. Having regard to the rival contentions and material on record. We find that u/s 251(1) of the Act, the CIT(A) has the power to confirm, reduce, enhance or annul the assessment in an appeal against an order of assessment. The Hon’ble Supreme Court in the case of Shapoorji

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

263 of the Act is bad in law and therefore need to be quashed and we order accordingly\". We are in agreement with such observations and findings of the Co-ordinate Bench of the Tribunal and while respectfully following the same, we hold that inasmuch as the assessee satisfied the conditions of section 80G of the Act, the assessee

PENNAR INDUSTRIES LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1),, HYDERABAD

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

Bench: Us:

263 of the Act to dislodge the possible and plausible view that was arrived at by the AO after carrying out necessary verifications regarding the allowability of the claim of the assessee company for deduction of bad debts 18.1. On merits, we find that the assessee company had written off the bad debts in its books of account

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

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, three appeals i

68 & 69 of the Act were deleted by the Ld.\nCIT(A) and the Hon'ble ITAT, Hyderabad Vide its orders in Appeal\nno.10421/2019-20 dt. 21.04.2022 and ITA No. 146/Hyd/2022 dt.\n19.07.2022.\n9.\nThe learned CIT(A) ought to have considered that several Judicial\nrulings and Circulars of the CBDT state that minor filing delays\nshould not deny tax exemptions

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

263 r.w.s.\n144B of the Income-tax Act, 1961, on 24.09.2021 and determined\nthe total income at Rs. 28,46,91,790/- by making additions of Rs.\n8,77,278/- towards disallowance of interest on TDS and further\ndisallowance of EPF & ESI under Section 36(1)(va) for Rs.\n3,66,095/-, addition towards disallowance of interest expenditure\nunder

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

263 of the Act is bad in law and therefore need to be\nquashed and we order accordingly\".\n16.\nWe are in agreement with such observations and findings of the\nCo-ordinate Bench of the Tribunal and while respectfully following the\nsame, we hold that inasmuch as the assessee satisfied the conditions\nof section

MYLAN LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER INCOME TAX , CIRCLE-5 (1) , HYDERABAD

In the result, the ground no

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

68,869/- vide his order dated 31.01.2018. Later on, Ld. PCIT called for the record for examination u/s. 263 of the Act. After perusal of the record, Ld. PCIT held that the amount of Rs.340.45 Crores paid to Pfizer is a capital expenditure and is not for the business expediency of ASPL. On the aspect of the liquidated damages