F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

68,190/- only. The return of income was processed under section 143(1) of the Act wherein the CPC disallowed the claim of gratuity expenses for Rs. 5,13,01,761/- as per the provision of section 43B

SREE KRISHNA AUTOMOTIVES HYDERABAD PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Sree Krishna Automotives Vs. Dy. Cit, Hyderabad (P) Ltd Circle 3(1) Hyderabad Hyderabad Pan:Aakcs5353H (Appellant) (Respondent) Assessee By: Shri K.C. Devdas, Ca Revenue By: Sri K.P.R.R. Murty, Dr Date Of Hearing: 12/07/2022 Date Of Pronouncement: 14/07/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 1.10.2021 Of The Learned Cit (A)- Nfac, Relating To A.Y.2019-20. 2. Although A Number Of Grounds Have Been Raised By The Assessee, However, These All Relate To The Order Of The Cit(A)/Nfac In Sustaining The Addition Of Rs.30,53,317/- Made By The Assessing Officer U/S 36 Of The I.T. Act On A/C Of Delayed Payment Of Pf & Esi.

43B Rs. 68,790 Disallowed an amount towards profit on Rs.59,343 sale assets 5. The learned CIT (A) NFAC deleted the addition of Rs.68,790/- on account of payment of gratuity and Rs.59,343/- towards profit on sale of assets. However, he sustained the addition of Rs.30,53,317/- on account of payment towards employees’ contribution

DARSHAN VIJAYSINH BHATIA,HYDERABAD vs. THE COMMISSIONER OF INCOME TAX APPEAL, FACELESS CENTER DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri A. Mohan Alankamony & Sri S.S. Godara

43B of the Act by inserting Explanation 5 to the said section to clarify that the provisions of the said section do not apply and deemed to never have been applied to a sum received by the assessee from any of his employees to which provisions of sub-clause (x) of clause (24) of section 2 applies

DARSHAN V BHATIA,HYDERABAD vs. THE COMMISSIONER OF INCOME TAX APPEAL, DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri A. Mohan Alankamony & Sri S.S. Godara

43B of the Act by inserting Explanation 5 to the said section to clarify that the provisions of the said section do not apply and deemed to never have been applied to a sum received by the assessee from any of his employees to which provisions of sub-clause (x) of clause (24) of section 2 applies

CASPIAN IMPACT INVESTMENTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.749/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Caspian Impact Vs. Dy.Cit Investments Private Ltd, Circle 1(1) Hyderabad Hyderabad Pan:Aadcs4132K (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Hiten Thakkar, Advocate राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 25/09/2025 घोषणा की तारीख/Pronouncement: 03/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Caspian Impact Investments Private Limited, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Addl/Jcit (A)-1, Mumbai (“Ld. First Appellate Authority”), Dated 27.02.2025 For The A.Y. 2019-20. 2. The Assessee Has Raised The Following Grounds Of Appeal:

68,147/- under section 115JB of the Act. The second revised return was processed by CPC under section 143(1)(a) of the Act on 09.03.2021. CPC made the additions of Rs.1,64,955/- under section 36(1)(iii), Rs.13,22,458/- under section 37(1) and Rs.10,41,545/- under section 43B

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

68 of the Act: Rs.16,19,208/-; (v) disallowance under section 43B of the Act: Rs.6,08,594/-; (vi) addition

C & K MANAGEMENT LIMITED ,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-1(3), 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 Sahuassessment Year: 2013-14 C&K Management Ltd., Vs. Income-Tax Officer, Secunderabad. Ward – 1(3), Hyderabad. Pan – Aabcc 4481D (Appellant) (Respondent) Assessee By: Shri J. Maruthi Raghuram Revenue By: Shri Sunku Srinivas Date Of Hearing: 09/09/2021 Date Of Pronouncement: 04/10/2021 O R D E R Per L.P. Sahu, A.M.: This Appeal Filed By The Assessee Is Directed Against Cit(A) - 1, Hyderabad’S Order Dated 04/05/2018 For Ay 2013-14 Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961 ; In Short “The Act, On The Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case, The Order Of The Ld. Cit(A) & Ld. Ao Is Contrary To Law & Facts Of The Case. 2. The Ld. Ao Disallowed Rs.58,170/-W.R.T Pf & Esi Payments Stating This Amount Is Not Paid Before The Due

Section 43B by inserting corresponding Explanations that although the impugned employees provident fund comes under the former provision only, the same is :- 6 -: C&K Management Ltd., Sec’bad. applicable from 01-04-2021 onwards. Meaning thereby that the legislature itself has condoned the impugned default before 01-04-2021. We thus delete the impugned employees provident fund disallowance

SRI ABHISHEK STEEL AND POWER LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

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

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahuassessment Year: 2011-12 Sri Abhishek Steel & Vs. Dy. Commissioner Of Power Ltd., Hyderabad. Income-Tax, Circle – 1(1), Pan – Aacca9140Q Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohana Rao Revenue By Shri Sunil Kumar Pandey Date Of Hearing: 01/02/2021 Date Of Pronouncement: 19/04/2021

43B of the Act, Since liability to pay excise duty has not arisen under the governing laws of Excise Duty. 7. The Ld. CIT(A) ought to have appreciated that the liability towards Excise Duty has been discharged in subsequent months when the closing stock was sold. 8. The Ld. CIT(A) ought to have appreciated that all the expenditure

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

section 43B of the Act for provision made for an approved gratuity fund of Rs. 50,07,765/- which is deductible u/s 40A(7) of the Act. :- 7 -: ITA Nos. 907/Hyd/2019 & 252/H/18 Bharat Financial Inclusion Ltd., Hyd. 7.4 Following the conclusions drawn at para 7.2 in respect of Revenue’ appeal (supra), we set aside the order

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

section 43B of the Act for provision made for an approved gratuity fund of Rs. 50,07,765/- which is deductible u/s 40A(7) of the Act. :- 7 -: ITA Nos. 907/Hyd/2019 & 252/H/18 Bharat Financial Inclusion Ltd., Hyd. 7.4 Following the conclusions drawn at para 7.2 in respect of Revenue’ appeal (supra), we set aside the order

ASST, COMMISSIONER OF INCOME TAX, CIRCLE-15(1), HYDERABAD vs. K. SESHAGIRI RAO & CO.,, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2009-10 Assistant Commissioner Of Vs. M/S. K. Seshagiri Rao & Co, Income Tax, Circle-15(1), 2-98/3, Block-B, Kakateeya Hyderabad. Nagar, Habsiguda, Hyderabad-500 007. (Appellant) (Respondent) Assessee By: Sri K.C. Devdas Revenue By: Sri Murali Mohan, Dr Date Of Hearing: 16/01/2020 Date Of Pronouncement: 19/03/2020 Order Per A. Mohan Alankamony, Am.:

section 43B of the Act and Rs. 1,16,73,049/- towards difference of income disclosed in the books of accounts and the income stated in Form 26AS. On appeal, the Ld. CIT (A) restricted the disallowance of expenditure to 5%; granted relief for Rs. 26,27,677/- in respect of addition towards sundry creditors and further deleted

M/S COUNTRY CLUB (INDIA) LTD,HYDERABAD vs. ADDL. CIT, RANGE-1, HYDERABAD

In the result, assessee’s appeal is treated as partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmancountry Club Hospitality & Vs Addl. Cit, Range-1 Holidays Ltd Hyderabad Hyderabad Pan: Aaacc 9376 B (Appellant) (Respondent) Asstt. Commissioner Of Country Club Hospitality & Income Tax, Circle 1(2) Vs Holidays Ltd Hyderabad Hyderabad Pan: Aaacc 9376 B (Appellant) (Respondent)

68,613 as paid in violation of section 40A(3) of the Act and he accordingly disallowed the same. Aggrieved, the assessee preferred an appeal before the CIT (A) who confirmed the addition by holding that the assessee has not produced any evidence in support of its contention that the payment in question were below Rs.20,000 on different

ACIT, CIRCLE-1(2), HYDERABAD vs. M/S. COUNTRY CLUB (I) LTD,, HYDERABAD

In the result, assessee’s appeal is treated as partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmancountry Club Hospitality & Vs Addl. Cit, Range-1 Holidays Ltd Hyderabad Hyderabad Pan: Aaacc 9376 B (Appellant) (Respondent) Asstt. Commissioner Of Country Club Hospitality & Income Tax, Circle 1(2) Vs Holidays Ltd Hyderabad Hyderabad Pan: Aaacc 9376 B (Appellant) (Respondent)

68,613 as paid in violation of section 40A(3) of the Act and he accordingly disallowed the same. Aggrieved, the assessee preferred an appeal before the CIT (A) who confirmed the addition by holding that the assessee has not produced any evidence in support of its contention that the payment in question were below Rs.20,000 on different

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

Bench: Us:

43B of the Act the income of the assessee company was determined at Rs. 6,55,06,350/-. 4. During the course of the assessment proceedings, the AO made a reference to the Transfer Pricing Officer (for short, “TPO”) under section 92CA(1) of the Act for determining the Arm’s Length Price (for short, “ALP”) of the international

TELANGANA STATE HOUSING CORPORATION LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

43B on the mistaken assumption that the outstanding interest has been converted into fresh loan. 5. The Ld. CIT-A and the AO ought to have appreciated that the fresh loan obtained of Rs.2280,00,00,000/- has no link to the repayment of interest amount of 3 ITA.No.554/Hyd./2024 Rs.547,50,70,481/- and hence ought

ITO, WARD-3(2), HYD, HYDERABAD vs. R.K. INFRA & ENGINEERING (INDIA) PVT.LTD., HYD, HYDERABAD

In the result, appeal of the revenue and the CO of the assessee are dismissed

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

68,442/- Since the assessee has not deducted the tax on payments of interest to the above concerns and when the AO put the same before the assessee in the show cause notice, in reply, the assessee company relied on Board’s Circular and stated that the hire purchase transaction does not attract TDS provisions. The AO observed that

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

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

68,70,494/- as provision made for bad and doubtful debts as against the actual provision for bad and doubtful debts made by the appellant in its books of account for Rs.785,63,70,494/-. The facts are not clear. The Assessing Officer observed that as per note on accounts under Schedule 18 at point 10.1 on page

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

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

68,70,494/- as provision made for bad and doubtful debts as against the actual provision for bad and doubtful debts made by the appellant in its books of account for Rs.785,63,70,494/-. The facts are not clear. The Assessing Officer observed that as per note on accounts under Schedule 18 at point 10.1 on page