DCIT., (INTERNATIONAL TAXATION)-1, HYDERABAD vs. SYAMA REDDY MALI REDDY, HYDERABAD

price by payment of kind or adjustment of old debt or other\nmonetary considerations. It was observed that if you sell a house and\nmake profit, pay Caesar (State) but if you buy a house or build another\nand thereby satisfy the conditions of Section 54, you were exempt. The\npurpose was plain; the symmetry was simple; the language

HIMASAGAR KRISHNA MUTHAPPAGARI,TIRUPATI vs. ITO., WARD-2(3), TIRUPATI

Bench: Us.

house, therefore, no adverse inferences were liable to be drawn as regards his claim of exemption raised u/s 54F of the Act. Elaborating further, it was the assessee's claim that though as per the terms of the original “agreement to purchase” a Villa No. 48 was allotted to him by the builder, but thereafter due to some internal problems

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

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

Transfer Pricing Officer (“Ld. TPO”) applied LIBOR for determining the Arm’s Length Price (“ALP”). In this regard, the Ld. AR submitted that, the issue under consideration was referred to Special Bench of this Tribunal and the Special Bench vide its order dated 29.01.2025, has adjudicated the issue at para no.23 of its order, which is to the following effect

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

Bench: Us:

Transfer Pricing analysis by promoting a more robust and relevant set of comparables for determining the arm's length price of international transactions entered into by the Assessee. Thus, the Panel finds no infirmity with TPO's findings and accordingly the objection raised by the Assessee are hereby rejected. 23 HighRadius Technologies Private Limited 2.5.10.8 In view of the above

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

transfer as 01.04.2011. By virtue of order of Hon’ble High Court, assessee receives shares of 11 companies which were merged with the assessee along with the other underlined properties. As per our understanding, there is a distinction between “receive of property being the shares of the amalgamating companies” and “underlying assets and transfer of said assets to the amalgamated

TARA CHAND BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3),, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. JHANSI RANI BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. SARAT GOPAL BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. TARA CHAND BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

KAVYA BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. KAVYA BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

transfer of property, the manner thereby was that the parties have agreed for consideration of Rs.2.45 lakhs whereas registered the property for a consideration of Rs.1,02,07,500/-. 15.5. The learned counsel for the assessee supporting the order of ld.CIT(A) submitted that initially parties were agreed for consideration of Rs.2.45 lakhs with certain terms and conditions

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

property right, exterior design or practical and new design or any other business or commercial rights of similar nature; (c). capital financing, including any type of long-term or short-term borrowing, lending or guarantee, purchase or sale of marketable securities Page 16 of 82 or any type advance, payments or deferred payment or receivable or any other debt arising

HETERO LABS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

property right, exterior design or practical and new design or any other business or commercial rights of similar nature; (c). capital financing, including any type of long-term or short-term borrowing, lending or guarantee, purchase or sale of marketable securities Page 16 of 82 or any type advance, payments or deferred payment or receivable or any other debt arising

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD, HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

property right, exterior design or practical and new design or any other business or commercial rights of similar nature; (c). capital financing, including any type of long-term or short-term borrowing, lending or guarantee, purchase or sale of marketable securities Page 16 of 82 or any type advance, payments or deferred payment or receivable or any other debt arising

ACIT., CENTRAL CIRCLE 3(4), HYDERABAD vs. HETERO LABS LIMITED, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

property right, exterior design or practical and new design or any other business or commercial rights of similar nature; (c). capital financing, including any type of long-term or short-term borrowing, lending or guarantee, purchase or sale of marketable securities Page 16 of 82 or any type advance, payments or deferred payment or receivable or any other debt arising

INCOME TAX OFFICER, WARD-1, CHITTOOR vs. G VIJAYASIMHA REDDY, BENGALURU

In the result, the appeal of Revenue in ITA

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

pricing of the flats and use of organized means of sale of flats shows that the arrangement was not' a simple financing arrangement but an adventure in nature of trade. 4. The department submits that the finding of the Ld. CIT(A) that the capital gain will be long term in nature is without any basis for reasons discussed