ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, MADHAPUR

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

801A of the I.T. Act. The assessee, therefore, prays the Hon'ble ITAT to kindly dismiss the appeals filed by the Revenue. 9. We have heard the rival submissions and perused the material on record. In the present case, the sole objection of the AO is that the infrastructure facility created by the assessee -- the formation of ‘Venkatadri Reservoir Bund

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, HYDERABAD

In the result, all the appeals of the Revenue are dismissed

801A of\nthe I.T. Act.\nThe assessee, therefore, prays the Hon'ble ITAT to kindly dismiss the\nappeals filed by the Revenue.\nWe have heard the rival submissions and perused the\nmaterial on record. In the present case, the sole objection of the\nAO is that the infrastructure facility created by the assessee\nthe formation of ‘Venkatadri Reservoir Bund' – does

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Transfer Pricing Officer (TPO) in respect of specified domestic transactions reported by the assessee company. The TPO, after examining the submissions and documentation furnished by the assessee company, passed an order under section 92CA(3) of the Act, determining the arm's length price (ALP) of the specified domestic transactions and did not propose any adjustment. 4. Thereafter

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Transfer Pricing Officer\n(TPO) in respect of specified domestic transactions reported by the\nassessee company. The TPO, after examining the submissions and\ndocumentation furnished by the assessee company, passed an order\nunder section 92CA(3) of the Act, determining the arm's length price\n(ALP) of the specified domestic transactions and did not propose any\nadjustment.\n4.\nThereafter

VALUELABS LLP,HYDERABAD vs. DCIT., CENTRAL CIRCLE 8(1), HYDERABAD

In the result, we uphold the order passed by the CIT(A) and\ndismiss the assessee's appeal

transfer of\n\"carbon credits”. The “Explanation” to section 115BBG of the Act defines\n\"carbon credits\" to mean, reduction of one tonne of carbon dioxide\nemissions or emissions of its equivalent gases, which is validated by the\nUnited Nations Framework on Climate Change (UNFCC) and which can\nbe traded in the market at its prevailing market price

SABIR , SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

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

801A.\n23.2 From the above reading, it is clear that prior to the insertion\nof the Finance Act, 2007, there was no such Explanation, and it\nwas only by way of the Explanation that a specific category of\npersons executing works contracts was excluded from Section\n80IA of the Act. This exclusion applied only to works contracts'\nawarded

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

transfer pricing adjustment.\n4.\nThereafter, the Ld. PCIT invoked provisions of section 263 of\nthe Act and issued notice to the assessee on 08.03.2024. The Ld.\nPCIT recorded that the Ld. AO during scrutiny assessment failed to\nexamine two specific issues, which is covered under Explanation\n2(a) to section 263 of the Act, thereby rendering the order erroneous\nand

KNR CONSTRUCTIONS LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Price (\"ALP\").\n3.1 The Ld. TPO, vide order passed under section 92CA(3)\nof the Act dated 31.07.2021, proposed an upward adjustment of\nRs.121,50,70,645/-. Based on the said order, the Ld. AO passed a\ndraft assessment order under section 144C of the Act on\n08.09.2021. Against the draft order of Ld. AO, the assessee filed\nobjections before

CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

801A(4) of the Act. Thus, the grounds of appeal filed by the assessee are dismissed.” 6. Feeling aggrieved with the order of LD.CIT(A), the assessee is now in appeal before us. 6.1. First, we will deal with the additional grounds raised by the assessee. 7. Before us, the ld.AR submitted that the assessment order was passed

SABIR, SEW 7 PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

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

801A.\n\n23.2 From the above reading, it is clear that prior to the insertion\nof the Finance Act, 2007, there was no such Explanation, and it\nwas only by way of the Explanation that a specific category of\npersons executing works contracts was excluded from Section\n80IA of the Act. This exclusion applied only to works contracts'\nawarded

SABIR, SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

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

801A(4) of the Act.\n\n7.9 At this juncture, it is important to note that there is a clear difference\nand distinction between the terms \"developer\" and \"contractor\". Further,\nnormally, any \"works contract\" awarded by the Government to a\ncontractor by way of a tender process would fall under the ambit of the\ncontractor rather than developer. This issue