MSN INSTITUTE OF MEDICAL SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

263 of\nthe Act do not provide for revising the \"satisfaction note\"\nrecorded by the Assessing Officer, which is completely\ndifferent and distinct in its nature from the order passed by\nthe Assessing Officer. Hence, the appellant submits that the\nsatisfaction note recorded by the Assessing Officer for\nenabling him to assume jurisdiction to issue notices\nu/sec.153C is final

PRATHIMA RESORTS & RESTAURANTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

263 of\nthe Act do not provide for revising the \"satisfaction note\"\nrecorded by the Assessing Officer, which is completely\ndifferent and distinct in its nature from the order passed by\nthe Assessing Officer. Hence, the appellant submits that the\nsatisfaction note recorded by the Assessing Officer for\nenabling him to assume jurisdiction to issue notices\nu/sec.153C is final

ADRIJA FARMS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

DAKSHAYANI HORTICULTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

PRAYAGA GREEN MEADOWS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

SPARK VIDYUTH PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

PRATHIMA EGGSEL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

MSN INSTITUTE OF MEDICAL SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

PRATHIMA RESORTS & RESTAURANTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

PRATHIMA EGGSEL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 of the Act do not provide for revising the "satisfaction note" recorded by the Assessing Officer, which is completely different and distinct in its nature from the order passed by the Assessing Officer. Hence, the appellant submits that the satisfaction note recorded by the Assessing Officer for enabling him to assume jurisdiction to issue notices u/sec.153C is final

LYCOS INTERNET LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

263 of the I.T Act, 1961 and the assessing officer is directed to examine the above discrepancies and assess the correct income by redoing the assessment afresh after affording an opportunity of being heard to the assessee. The assessment order dated 29 03 2016 stands revised accordingly”.\n\n18.\nThus,, the order of the Assessing Officer was set aside/revised

CAMBRIDGE TECHNOLOGY ENTERPRISES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.536/Hyd/2019 (निर्धारण वर्ा/Assessment Year: 2012-13) M/S Cambridge Technology Vs. Dcit Enterprises Limited Circle-1(2) Hyderabad Hyderabad [Pan :Aaacu3358G] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri Shiva Sewak, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 28/10/2024 घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.03.2019 Of The Learned Principal Commissioner Of Income Tax [Ld.Pcit], Hyderabad Pertaining To A.Y.2012-13. 2. The Brief Facts Of The Case Are That The Assessee Company, Engaged In The Business Of Rendering Software Services, Filed Its Return Of Income For The A.Y.2012-13 On 26.09.2012, Admitting Total Income Of Rs.4,05,55,380/- Under Normal Provisions Of Income Tax Act, 1961 (“The Act”) & Rs.1,47,09173/-

transfer pricing adjustment. The case has been subsequently taken up for revision proceedings and accordingly show cause notice u/s 263

SRI EDUPAYALA VANA DURGA BHAVANI,HYDERABAD vs. INCOME TAX OFFICER, WARD-1, SANGAREDDY

Bench: Us:

revised by him u/s 263 of the Act. On a perusal of the SCN, dated 15.12.2023 (supra), it transpires that the Pr. CIT had observed that the A.O, based on the information that the assessee during the subject year had made cash deposits of Rs. 2,48,64,238/- in its bank account, but not filed its return of income

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G.\Nand\Nshri Ravish Sood\Nआ.अपी.सं /Ita No.917/Hyd/2024\N(निर्धारण वर्ष/Assessment Year:2020-21)\Nshakti Hormann Private\Nlimited,\Nhyderabad.\Nvs. Dcit,\Ncircle-3(1),\Nhyderabad.\Npan: Aadcs4024Q\N(Appellant)\N(Respondent)\Nनिर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao,\Nca\Nराजस्व द्वारा / Revenue By: Ms. U. Mini Chandran,\Ncit-Dr\Nसुनवाई की तारीख /Date Of Hearing: 15/10/2025\Nघोषणा की तारीख / Date Of 19/12/2025\Npronouncement:\Nआदेश / Order\Nper. Ravish Sood, J.M:\Nthe Present Appeal Filed By The Assessee Company Is Directed\Nagainst The Final Assessment Order Passed By The Assessing Officer (For\Nshort, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The\Nincome Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The\N Assessment Year (Ay) 2020-21. The Assessee Company Has Assailed\Nthe Impugned Order Passed By The Cit(A) On The Following Grounds Of\Nappeal Before Us:\N1. On The Facts & In The Circumstances Of The Case, The Final Assessment\Norder Passed U/S 143(3) R.W.S.144C(13) Of The Act Dated 25.07.2024 By\Nthe Ao & Also The Order Passed U/S 92Ca (3) Dt 30.07.2023 By The Tpo\Nare Bad In The Eyes Of Law & Thus, Unsustainable To The Test Of Appeal.\N2.0 The Final Assessment Order Passed U/S 143(3) R.W.S.144C(13) R.W.S.144B\Nis Beyond The Time Limit Prescribed U/S 153 Of The Act.\N2.

u/s 93B\nof the Act.\n5.9\nThe Ld. AO ought to have appreciated that no interest can be charged\non receivables when the principal transaction is at arms length price which\nhas been accepted by the TPO.\n5.10 The Ld. AO ought to have appreciated that the outstanding\nreceivables are foreign currency receivables and that the same have

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

Bench: Us.

u/s 147 r.w.s. 144B of the Act, dated 22-03-2022. 13. Before proceeding any further, we deem it fit to cull out the provisions of Section 263 of the Act, which reads as under: “263. Revision of orders prejudicial to revenue. (1)The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

u/s 80-IC/801AB/10AA of the Act. 11.4. Further the Ld. A.O/Hon'ble DRP, ignored the order of Hon'ble ITAT in Appellant own case for the previous assessment years wherein the Hon'ble ITAT has ruled in favour of Appellant. The Appellant requests, to consider each of the above grounds of appeal without prejudice to each other and reserves

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

u/s 80-IC/801AB/10AA of the Act. 11.4. Further the Ld. A.O/Hon'ble DRP, ignored the order of Hon'ble ITAT in Appellant own case for the previous assessment years wherein the Hon'ble ITAT has ruled in favour of Appellant. The Appellant requests, to consider each of the above grounds of appeal without prejudice to each other and reserves

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD vs. LYCOS INTERNET LIMITED,, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1550/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Asstt. Commissioner Of Vs. Lycos Internet Ltd Income Tax, Circle 16 (1) Hyderabad Hyderabad Pan:Aaacl5827B (Appellant) (Respondent) आ.अपी.सं /Ita No.1769/Hyd/2018 (िनधा"रण वष"/Assessment Year: 2012-13) Lycos Internet Ltd Vs. Asstt. Commissioner Of Hyderabad Income Tax, Circle 16 (1) Pan:Aaacl5827B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/12/2024 घोषणा की तारीख/Pronouncement: 22/01/2025 आदेश/Order Per Vijay Pal Raothese Are Two Appeals, One By The Department Against The Order Dated 23/06/2017 Of The Learned Cit (A) & Another By The Assessee Against The Revision Order Dated 26/02/2018 Passed

263 of the I.T Act, 1961 and the assessing officer is directed to examine the above discrepancies and assess the correct income by redoing the assessment afresh after affording an opportunity of being heard to the assessee. The assessment order dated 29 03 2016 stands revised accordingly”. 18. Thus,, the order of the Assessing Officer was set aside/revised

IVY COMPTECH PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 2(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2020-21 Ivy Competech Private Limited, Vs. The Deputy Commissioner Of Income Tax, Hyderabad. Circle 2(1), Hyderabad. Pan : Aaac18884K. (Appellant) (Respondent) Assessee By: Shri Nageswara Rao, Advocate. Revenue By: Ms. M. Narmada, Cit-Dr Date Of Hearing: 20.01.2025 (Hybrid Hearing) Date Of Pronouncement: 04.02.2025

Transfer Pricing Officer revised the adjustment made u/s. 92CA in the order dated 31.03.2023. In the order dated 31.03.2023, the TPO made following adjustments: S.No. Description Adjustment u/s 92CA (in Rs.) 1 Provision of Software development 67,95,430/- expenses 2 Interest on delayed receivables 11,35,997/- Total Adjustments 79,30,427/- As per directions