M/S NAGARJUNA FERTILIZERS AND CHEMICALS LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

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

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

224,82,67,271/- and book profit u/s 115JB at Rs. 135,95,52,310/-. The return was processed u/s 143(1) and Nagarjuna Fertilizers and Chemicals Ltd., Hyd. subsequently the case was selected for scrutiny. Accordingly, statutory notices were issued and the assessee filed the information as called for. 2.1 As the assessee entered into international transactions

M/S KANTAR GDC INDIA PVT. LTD. (FORMERLY TNS INDIA PVT LTD),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

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

Bench: Shri Mahavir Singh & Shri Manjunatha, G.आ.अपी.सं /Ita No.2261/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2013-14) M/S. Kantar Gdc India (P) Vs. Dy. C. I. T. Ltd (Formerly Tns India (P) Circle 2(2) Ltd, Hyderabad Hyderabad Pan:Aabcn2278F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Harpreet Singh Ajmani राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order

TRANSFER PRICING MATTERS: ALP for management fees 1. Determining the arm's length price in respect of payment towards management services paid to AE as 'Nil': 2. Determining the ALP as NIL, without appreciating that the cost towards management fees is already considered as part of the operating cost in respect of the services transactions, which have been determined

MAHARSHI GOGINENI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result, appeal of assessee is allowed in part

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

price by payment of kind or adjustment of old debt or other monetary considerations. It was observed that if you sell a house and make profit, pay Caesar (State) but if you buy a house or build another and thereby satisfy Page 4 of 8 the conditions of Section 54, you were exempt. The purpose was plain; the symmetry

DIWAKAR REDDY CHINTAKUNTALA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(3), HYDERABAD

In the result, appeal in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

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

INDUMATI CHINTAKUNTALA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(3), HYDERABAD

In the result, appeal in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

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

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

UNITED STATES PHARMACOPEIA INDIA PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(2), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2013-14 United States Pharmacopeia Vs. Dy. Commissioner Of Income- India Pvt. Ltd., Hyderabad Tax, Circle – 17(2), Hyderabad. Pan – Aaacu7542C

Transfer Pricing Officer (TPO) for determining ALP. Assessee has entered into following international transactions: AE Nature of transaction Amount (Rs. Provision of testing & 57,78,86,457 certification services Provision of customer 3,77,57,019 outreach services USP Holding Interest on ECB Loan 1,33,79,306 LLC, USA Repayment of ECB Loan 3,89,62,000 ECB Loan

K LAXMA REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

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

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

224 of the I.T. Act. According to him, since the Assessing Officer has passed the order without making any enquiry which should have been made or the order is passed allowing a relief without enquiry, the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue and therefore, he set aside the order

K VIJAYA BHASKAR REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

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

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

224 of the I.T. Act. According to him, since the Assessing Officer has passed the order without making any enquiry which should have been made or the order is passed allowing a relief without enquiry, the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue and therefore, he set aside the order

N JAIDEEP REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

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

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

224 of the I.T. Act. According to him, since the Assessing Officer has passed the order without making any enquiry which should have been made or the order is passed allowing a relief without enquiry, the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue and therefore, he set aside the order

N JAIVEER REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

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

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

224 of the I.T. Act. According to him, since the Assessing Officer has passed the order without making any enquiry which should have been made or the order is passed allowing a relief without enquiry, the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue and therefore, he set aside the order

CATERPILLAR GLOBAL MINING EUROPE GMBH-INDIA PROJECT OFFICE,KARIMNAGAR vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATION TAXATION-1), HYDERABAD

Appeals are partly allowed

Bench: Shri S.S. Godara & Shri L. P. Sahu

224 dated 21.11.2006 for provision of services for introduction of Continuous Miner Technology at GDK11A Underground Mine required to achieve the Annual Guaranteed Production. 30. Clause 21 provides that in case any tax, duty and/or levy etc., is imposed or assessed in India on DBT or its Project Office under this contract, other than mentioned in clause

CATERPILLAR GLOBAL MINING EUROPE GMBH,PEDDAPALLI vs. ASSISTANT OF INCOME TAX -1,INTERNATIONAL TAXATION ,HYDERABAD, HYDERABAD

Appeals are partly allowed

Bench: Shri S.S. Godara & Shri L. P. Sahu

224 dated 21.11.2006 for provision of services for introduction of Continuous Miner Technology at GDK11A Underground Mine required to achieve the Annual Guaranteed Production. 30. Clause 21 provides that in case any tax, duty and/or levy etc., is imposed or assessed in India on DBT or its Project Office under this contract, other than mentioned in clause

CATERPILLAR GLOBAL MINING EUROPE GMBH,PEDDAPALLI vs. ASST. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION)-1, HYDERABAD

Appeals are partly allowed

Bench: Shri S.S. Godara & Shri L. P. Sahu

224 dated 21.11.2006 for provision of services for introduction of Continuous Miner Technology at GDK11A Underground Mine required to achieve the Annual Guaranteed Production. 30. Clause 21 provides that in case any tax, duty and/or levy etc., is imposed or assessed in India on DBT or its Project Office under this contract, other than mentioned in clause

CSATERRPILLAR GLOBAL MINING EUROPE GMBH,GODAVARIKHANI vs. DEPUTY COMMISSIONER OF INCOME TAX-I (INTERNATIONAL TAXATION), HYDERABAD

Appeals are partly allowed

Bench: Shri S.S. Godara & Shri L. P. Sahu

224 dated 21.11.2006 for provision of services for introduction of Continuous Miner Technology at GDK11A Underground Mine required to achieve the Annual Guaranteed Production. 30. Clause 21 provides that in case any tax, duty and/or levy etc., is imposed or assessed in India on DBT or its Project Office under this contract, other than mentioned in clause

CATTERPILLAR MINING EUROPE GMBH-INDIA PROJECT OFFICE, KARIMNAGAR,KARIMNAGAR vs. DCIT-1, INTERNATIONAL TAXATION, HYDERABAD, HYDERABAD

Appeals are partly allowed

Bench: Shri S.S. Godara & Shri L. P. Sahu

224 dated 21.11.2006 for provision of services for introduction of Continuous Miner Technology at GDK11A Underground Mine required to achieve the Annual Guaranteed Production. 30. Clause 21 provides that in case any tax, duty and/or levy etc., is imposed or assessed in India on DBT or its Project Office under this contract, other than mentioned in clause

PATHFINDER PUBLISHING PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE -16(2), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

transfer at general body meeting of the company; (iii) reserve and surplus, by whatever name called, even if the resulting figure is negative, other than those set apart towards depreciation; (iv) any amount representing provision for taxation, other than amount of tax paid as deduction or collection at source or as advance tax payment as reduced by the amount

SRINIVAS SHAH RADRARAJU ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.957/Hyd/2019 (निर्धारण वर्ा/Assessment Year: 2014-15) Srinivas Shah Rudraraju Vs. Dcit, Circle-2(1) Hyderabad Hyderabad [Pan :Afcpr1979L] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 15/01/2025 घोर्णध की तधरीख/Date Of 05/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)]-2, Guntur, Pertaining To A.Y.2014-15. 2. The Brief Facts Of The Case Are That, The Assessee Is An Individual, Filed His Return Of Income For The A.Y.2014-15 On 31.03.2015, Admitting Total Income Of Rs.53,50,976/-. The Case Was Selected For Scrutiny Under Cass For The Reason ‘Suspicious Long Term Capital Gain On Shares’ & During The Course Of Assessment Proceedings, The Assessing Officer, Noticed That The 2 Srinivas Shah Rudra Raju

224/- as unexplained cash credit u/s 68 of the Act. The Assessing Officer had also made addition of Rs.4,61,484/- towards alleged commission paid to brokers, who facilitated the transactions of purchase and sale of shares as unexplained expenditure. 3. Being aggrieved by the assessment order, the assessee preferred an appeal before the CIT(A). Before the Ld.CIT