SRINIVASA REDDY YETURU,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1898/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Srinivasa Reddy Yeturu, Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aalpy0486H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, C.A राज" व "ारा/Revenue By: Shri Ashuthosh Pradhan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10/12/2025 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee, Which Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), 11, Hyderabad, Dated 01/10/2025, For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

68,582/- only @ Rs.1,87,433/- per acre. However, the evidence found during the search clearly shows that the assessee has agreed to purchase 1 acre of land @ Rs.1.51 crores and also paid a sum of Rs.2 crore by way of cash on 31/10/2021 to the agreement holder. From the above, it is very clear that the assessee has paid

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

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 - the period of two weeks -is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

MAITHRI LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

433 (SC) and\nsubmitted that, in order to invoke provisions of Section 2(22)(e), two\nfactors must be considered: whether the payment was a loan or\nadvance and whether on the date of payment there existed\naccumulated profits. Unless the transactions are in the nature of\nloans and advances, the provisions of Section 2(22)(e) cannot

ACIT., CENTRAL CIRCLE-2(4), , HYDERABAD vs. M/S. MAITHRI LABORATORIES PRIVATE LIMITED, HYDERABAD

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

433 (SC) and submitted that, in order to invoke provisions of Section 2(22)(e), two factors must be considered: whether the payment was a loan or advance and whether on the date of payment there existed accumulated profits. Unless the transactions are in the nature of loans and advances, the provisions of Section 2(22)(e) cannot

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

433 (SC) and submitted that, in order to invoke provisions of Section 2(22)(e), two factors must be considered: whether the payment was a loan or advance and whether on the date of payment there existed accumulated profits. Unless the transactions are in the nature of loans and advances, the provisions of Section 2(22)(e) cannot

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

433 (SC) and submitted that, in order to invoke provisions of Section 2(22)(e), two factors must be considered: whether the payment was a loan or advance and whether on the date of payment there existed accumulated profits. Unless the transactions are in the nature of loans and advances, the provisions of Section 2(22)(e) cannot

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

In the result, the appeals filed by the assessee for assessment years 2019-20 and 2020-21 are partly allowed

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

433 (SC) and submitted that, in order to invoke provisions of Section 2(22)(e), two factors must be considered: whether the payment was a loan or advance and whether on the date of payment there existed accumulated profits. Unless the transactions are in the nature of loans and advances, the provisions of Section 2(22)(e) cannot

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

In the result, the appeals filed by the assessee for assessment years 2019-20 and 2020-21 are partly allowed

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

433 (SC) and submitted that, in order to invoke provisions of Section 2(22)(e), two factors must be considered: whether the payment was a loan or advance and whether on the date of payment there existed accumulated profits. Unless the transactions are in the nature of loans and advances, the provisions of Section 2(22)(e) cannot

MANAVEEYA DEVELOPMENT & FINANCE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.480/Hyd/2025 Assessment Year 2020-2021 Manaveeya Development & Finance Private Limited, Hyderabad. The Dcit, Circle-5(1), Vs. Pin – 500 034. Hyderabad – 500 004. Telangana. Pan Aaecm1085E (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca B Satyanarayana Murthy राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 26.11.2025 घोषणा की तारीख/Pronouncement: 24.12.2025 आदेश/Order

68,419/- was added back towards interest paid u/s.94B', out of payable interest of Rs.58,56,47,549/- to its AE. However, as seen from EBITDA, it was computed at Rs. 162,29,30,433/- as against the actual Rs.129.26 lakh for computing allowable interest u/s.94B. this omission resulted in excess claim of expenditure towards interest payable to AE' u/s.94B

SATYANARAYANA REDDY MANNE,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeal filed by the Assessee is allowed and appeal filed by the Revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

68,051 addition to 100% of purchases considered above Balance excess payments 241,53,50,035 1,53,47,177 treated as “advance or loan” constituting deemed dividend Aggregate deemed dividend for 243,06,97,212 AY 2019-20 45 ITA.Nos.382 & 472/Hyd./2025 Particulars A/c of MSN Laboratories Pvt Ltd in the books of the appellant. Amount

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

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

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

68,25,000/- - - - - in subsidiary Corporate 13,58,87,500/- - - - - Guarantee M/s BS Ltd., Hyd. 2.4 Analysis of the Transaction: As per the audited statement of accounts the financials of the assessee are as under: Description Amount (in Rs.) Operating revenue 1513,50,23,981/- Operating cost 1395,66,78,642/- Operating profit 117,83,45,339/- OP/TC 8.44% OP/sales

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 133(6) of the I.T. Act, the TPO has the power to call for the necessary details from the comparable companies. It is seen that the Assessing Officer/TPO has exercised this power to call for details with regard to the various companies. As seen from the annual report of Foursoft Limited which is reproduced at page

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 133(6) of the I.T. Act, the TPO has the power to call for the necessary details from the comparable companies. It is seen that the Assessing Officer/TPO has exercised this power to call for details with regard to the various companies. As seen from the annual report of Foursoft Limited which is reproduced at page

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

In the result, ground of appeal No

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singhassessment Year:2014-15

68,17,09,000 24.03 Ltd 5 Tech Mahindra Ltd 1,70,13,90,00,000 1,37,39,35,00,000 32,74,55,00,000 23.83 (Seg.) 6 e-Infochips Ltd 2,05,61,12,437 1,13,59,89,199 92,01,23,238 81.00 7 Larsen & Toubro