NSL NAGAPATNAM POWER VENTURES PRIVATE LIMITED,HYDERABAD V. INCOME TAX OFFICER, WARD-16(1), HYDERABAD

CO 6/HYD/2025

AI Insights

The case involves NSL Nagapatnam Power Ventures Private Limited, which was penalized by the Assessing Officer for underreporting income by misreporting interest expenditure. The company had claimed deductions for interest expenditures related to investments and advances to its subsidiaries, which the Assessing Officer disallowed. The company contested the penalty, arguing that it had made full disclosures and that the disallowance was based on a difference of opinion, not misrepresentation. The Commissioner of Income-Tax (Appeals) agreed with the company, leading to the revenue's appeal to the Tribunal. The Tribunal supported the CIT(A)'s decision, emphasizing the company's compliance with the conditions for penalty immunity under Section 270AA.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 312279 (ITAT-HYDERABAD)
• Appeal Type: Cross Objection
• Pronouncement Date: 28-04-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB-B
• Assessment Year: 2018-2019
• Other Referred Cases: CIT Vs. Reliance Communications, S.A. Builders Vs. CIT(A), CIT vs. Dalmia Cement (Bhart) Ltd., CIT Vs. Reliance Petroproducts Pvt. Ltd., Price Waterhouse Coopers Pvt. Ltd. Vs. CIT and Another
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Difference of opinion; Commercial expediency; Wrong claim; Competent authority
• Section: 143(3); 271(1)(c); 270AA

Judgement Text

"आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad श्री रवीश सूद, माननीय न्याययक सदस्य एवं श्री मिुसूदन सावडिया, माननीय लेखा सदस्य SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No.28/Hyd/2025 (निर्धारण वर्ा/ Assessment Year:2018-19) Income Tax Officer, Ward – 16(1), Hyderabad. Vs. NSL Nagapatnam Power Ventures Private Limited, Hyderabad. PAN : AADCP9603L (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) C.O. No. 6/Hyd/2025 (In आयकरअपीलसं./I.T.A.No.28/Hyd/2025) (निर्धारण वर्ा/ Assessment Year:2018-19) NSL Nagapatnam Power Ventures Private Limited, Hyderabad. PAN : AADCP9603L Vs. Income Tax Officer, Ward – 16(1), Hyderabad. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented by : Shri A.V. Raghuram Advocate. राजस्व का प्रतततितित्व/ Department Represented by : Dr.Sachin Kumar, Sr.DR सुिवाई समाप्त होिे की ततति/ Date of Conclusion of Hearing : 22.04.2025 घोर्णध की तधरीख/Date of Pronouncement : 28.04.2025 2 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 O R D E R प्रनत रवीश सूद, जे.एम./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 Center (NFAC), Delhi, dated 27.11.2024, which in turn arises from the order passed by the Assessing Officer (for short “A.O.”) u/s 270A of the Income Tax Act, 1961 (for short, “the Act”) dated 02.03.2022 for A.Y. 2018-19. 2. The Revenue has assailed the impugned order on the following grounds of appeal before us: “1. The learned CIT(A) erred both in law and facts of the case. 2. The learned CIT(A) ought to have considered the fact that the penalty is levied on underreporting of income. 3. The learned CIT(A) erred in deleting the penalty levied despite the fact that the assessee society’s case falls under u/s 270A(9)(a) of the I.T. Act, 1961.” On the other hand, the assessee-company is before us as a Cross- Objector on the following grounds: 3 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 “1. On the facts and in the circumstances and in law, the Id. Commissioner of Income Tax (Appeals)/NFAC ought to have dealt with the grounds raised by the Appellant on merits in respect of penalty levied, and should have allowed the appeal even on merits. 2. The Ld. Commissioner of Income Tax (Appeals)/NFAC ought to have held that even on merits, the penalty is not leviable in as much as the Appellant has voluntarily disallowed substantial part of interest expenditure of Rs.2,08,92,623 and claimed set off of interest expenditure of Rs.22,37,411 against the interest income earned to such extent. 3. Without prejudice to above grounds, the Id. Commissioner of Income Tax (Appeals)/NFAC ought to have noticed that the AO erred in considering entire expenditure of Rs. 2,31,20,034 for the purpose of levy of penalty, which in itself indicates total lack of application of mind on part of the AO.” 3. Succinctly stated, the assessee company which is engaged in the business of power generation, had e-filed its return of income for the assessment year 2018-19, declaring a loss of Rs. (5,37,451/-). Subsequently, the case of the assessee company was selected for scrutiny assessment under Section 143(2) of the Act. 4. During the course of assessment proceedings, the A.O. observed that a perusal of the “balance sheet” of the assessee company for the subject year revealed borrowings of Rs. 493.31 crores from its holding, group and subsidiary companies on which interest of Rs.2,31,19,153/- was paid. On a perusal of the record, 4 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 the A.O. observed that the interest-bearing borrowed funds of the assessee company were routed for making viz., (i) Investments in subsidiary company: Rs.3,69,69,63,500/-; and (ii) Interest-free advances to subsidiary companies: Rs.31,92,87,397/-. Also, the assessee company had advanced interest-free loans to its related parties amounting to Rs.86,66,94,566/-. The A.O. observed that the assessee company had neither received any interest on loans advanced to related parties nor offered any income from its investments made in subsidiary companies. Accordingly, the A.O. called upon the assessee company to put forth an explanation as to why its claim for deduction of interest expenditure of Rs. 2,31,19,1153/- may not be disallowed. In reply, it was the claim of the assessee company that as it had a significant interest in the businesses of its three subsidiary companies which were engaged in the same line of business of power generation, therefore, the funds were infused in them for furtherance of its business. It was the claim of the assessee company that it being guided by business prudence had utilized its interest bearing borrowed funds for expanding its business activities by making investments and advances in its subsidiary companies. The assessee company, to 5 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 buttress its claim for deduction of the interest expenditure on the amounts invested/advanced in its three subsidiary companies, had drawn support from the judgment of the Hon'ble High Court of Bombay in the case of CIT Vs. Reliance Communications, ITA No. 3158 of 2019 and that of the Hon'ble Supreme Court in the case of S.A. Builders Vs. CIT(A) (2007) 288 ITR (1) (SC). Accordingly, it was the claim of the assessee company that as it had significant interest in the businesses of its subsidiaries and had utilized the borrowed funds for the furtherance of its business purposes, therefore, no disallowance of any part of interest expenditure pertaining to the funds so advanced/invested in the subsidiary companies was called for in its hands under Section 36(1)(iii) of the Act. However, the aforesaid explanation of the assessee company did not find favour with the A.O., who inter alia disallowed the same and vide his order passed under Section 143(3) read with Section 143(3A) and 143(3B) of the Act dated 09- 04-2021, determined its income at Rs. 16,99,960/-. The A.O. while culminating the assessment, initiated penalty proceedings under Section 270A(9)(a) qua the aforesaid disallowance of interest expenditure in the hands of the assessee company. 6 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 5. Thereafter, the A.O. vide his “Show Cause Notice” (SCN) dated 10.04.2021, called upon the assessee company to explain that as to why the penalty for underreporting in consequence of misreporting of income may not be imposed on it under Section 270A of the Act. Although, it was the claim of the assessee company that the disallowance of its claim for deduction of interest expenditure was merely based on a difference of opinion, and it had neither concealed its income nor furnished any inaccurate particulars, therefore, the penalty proceedings initiated in its case may be dropped, but the same did not find favour with the A.O. Apart from that, the assessee company, which had neither disputed the assessment order nor carried the matter any further in appeal, and had paid the entire amount of assessed tax liability of Rs. 16,99,960/- on 03.05.2021, had sought for immunity from imposition of penalty by submitting “Form 68” i.e., application as required per the mandate of Section 270AA of the Act. 6. As is discernible from the record, the assessee company had uploaded “Form 68” as an attachment along with its online submission of a letter dated 05.05.2021 in response to “Show- Cause Notice” (SCN) issued under Section 274 read with Section 7 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 270A of the Act dated 10.04.2021. The assessee company was, thereafter in receipt of a communication from the jurisdictional A.O. i.e. ITO-Ward 16(1), Hyderabad, wherein it was brought to its notice that “Form No.68” was required to be filed with him and not with the National Faceless Assessment Center (NFAC). The assessee company was further informed that as the A.O./NFAC, had brought the fact of submission of “Form 68” to the notice of the Jurisdictional Assessing Officer (JAO) vide its letter dated 10.01.2022, therefore, it was to be presumed that the same was filed on 10.01.2022. The A.O. based on his aforesaid observation, brought to the notice of the assessee company that it had failed to file “Form No.68” with the competent authority within the prescribed time-period. Apart from that, the assessee company was called upon to explain that now when the A.O. while framing the assessment vide his order passed under Section 143(3) dated 10.04.2021, had initiated penalty proceedings under Section 270A of the Act for underreporting of income as a consequence of misrepresentation or suppression of information, therefore, in the backdrop of the fact that its case was covered by the provisions of Section 270A(9)(a) of the Act, how it was eligible for seeking 8 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 immunity from imposition of penalty under Section 270AA of the Act? 7. In reply, the assessee company vide its letter dated 17-01- 2022, submitted before the JAO, viz., (i) that as the assessment was completed in its case by National e-Assessment, and it was nowhere provided in Section 270AA of the Act that “Form 68” should be filed before the concerned JAO, therefore, the submission of the same by the assessee company with the National Faceless Assessment Center (NFAC) on 05.05.2021 was well within the prescribed time-period and there was no justification to take the date of its filing as 10-01-2022; and (ii) that as the disallowance of the interest expenditure by the JAO was based on a mere difference of opinion, therefore, its case could not be brought within the meaning of underreporting of income on account of misrepresentation or suppression of facts. However, the above-said explanation of the assessee company did not find favour with the J.A.O., who declined to accept the contentions of the assessee company on both the aforementioned aspects and observed viz., (i). that the “Form 68” was filed by the assessee 9 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 company with the competent authority, i.e., JAO, only as on 10- 01-2022; and (ii). that as there was underreporting of income by the assessee company as a consequence of misrepresentation or suppression of facts, therefore, its application seeking immunity from levy of penalty could not be admitted under Section 270AA of the Act. Accordingly, the A.O. based on his deliberations, vide his order passed under Section 270A of the Act dated 02-03-2022, imposed on the assessee company a penalty of Rs. 1.64 crore (approx.) 8. The assessee company being aggrieved with the order of penalty imposed by the A.O. under Section 270A of the Act, dated 02-03-2022, carried the matter in appeal before the CIT(A), who, after deliberating on the contentions advanced by the assessee company qua the fulfillment of the conditions contemplated under Section 270AA of the Act, directed the A.O. to delete the penalty of Rs. 1.64 crore (supra) that was imposed by him under Section 270A of the Act, though subject to verification that the assessee company had not filed an appeal against the quantum 10 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 assessment. Accordingly, the CIT(A), based on his aforesaid observations partly allowed the appeal of the assessee company. 9. The revenue, being aggrieved with the order of the CIT(A), has carried the matter in appeal before us. 10. Dr. Sachin Kumar, learned Senior Departmental Representative (for short the “Ld. DR”), at the threshold of hearing of the appeal, submitted that the CIT(A) had grossly erred in law and facts of the case in vacating the penalty of Rs.1.64 crores (supra) that was imposed by the A.O. under Section 270A of the Act. Elaborating on his contention, the Ld. DR submitted that though the CIT(A) had observed that the assessee company fulfilled the conditions contemplated for seeking immunity from the imposition of the penalty under Section 270A of the Act, but he had grossly erred in not recording any observation for dislodging the view taken by the A.O. that the assessee company had underreported its income in consequence of misrepresentation or suppression of facts. The Ld. DR submitted that as observed by the AO the case of the assessee company was squarely covered by sub-section (9) of Section 270A of the Act, 11 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 therefore, it was divested of its right to claim immunity from imposition of penalty as per the mandate of Section 270AA of the Act. The Ld. DR to buttress his aforesaid claim has drawn our attention to the observations recorded by the A.O. in the body of the penalty order passed under Section 270A of the Act, dated 02.03.2022; as well as the order of assessment framed under Section 143(3) r.w.s. 143(3A) and 143(3B) of the Act dated 09.04.2021, wherein the subject penalty was initiated. Carrying his contention further, the Ld. DR submitted that as the CIT(A) had hushed through the matter and based on perverse observations vacated the penalty imposed by the AO under Section 270A of the Act, therefore, the order passed by him cannot be sustained and is liable to be struck down. 11. Per contra, Shri A.V. Raghuram, Advocate, the learned Authorized Representative (for short the “ld.AR”) for the assessee company, had vide his Cross-Objection assailed the imposition of penalty under Section 270A of the Act. Apart from that, the Ld. AR submitted that the Commissioner of Income-Tax (Appeals), NFAC had erred in not adjudicating the claim of the assessee company 12 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 that no penalty under Section 270A of the Act was called for in its case in the backdrop of the facts therein involved. Alternatively, the Ld. AR submitted that even otherwise the AO based on misconceived facts had wrongly quantified the amount of penalty imposed on the assessee company under Section 270A of the Act. The Ld. AR submitted that the assessee company had voluntarily disallowed the interest expenditure of Rs. 2.31 crore (supra) in its computation of income, Page 33 of APB. Carrying his contention further, the Ld. AR submitted that as the assessee company had only claimed netting of its interest income of Rs.22.37 lacs (approx.) against the aforesaid interest expenditure that it had already disallowed on a suo-moto basis while computing its taxable income, therefore, there was no justification for the A.O., to have quantified the penalty considering the entire amount of interest expenditure of Rs. 2.31 crore (supra). The Ld. AR, to buttress his aforesaid claim had taken us through the computation of income of the assessee company for the subject year at Page 33 of the APB. 13 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 12. On merits, the Ld. AR submitted that as the disallowance of the assessee's claim for deduction of interest expenditure was based on a mere difference of opinion, therefore, there was no justification for the A.O. to have visited the assessee company with any penalty under Section 270A of the Act. Apart from that, the Ld. AR submitted that now when the assessee company had made complete factual disclosure and correct representation of the entire set of the facts pertaining to its claim of deduction of interest expenditure and set-off of the same against its interest income, therefore, it could not be held to have either misrepresented or suppressed the facts on the said issue. 13. We have heard the Ld. Authorized Representatives of both the parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them to drive home their respective contentions. 14. As the Ld. AR for the assessee has assailed the sustainability of the penalty imposed by the A.O. under Section 270A of the Act, therefore, we deem it fit to first deal with the same. 14 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 15. Before proceeding any further, we may herein observe that though it is the claim of the Ld. DR that as the CIT(A) had failed to deal with the claim of the assessee company that no penalty under Section 270A of the Act was called for in its case, therefore, to the best the matter can only be restored to his file with a direction to adjudicate the same, but we are unable to find favour with the same. As the CIT(A) had observed that the assessee company cumulatively satisfied the set of pre-conditions contemplated under Section 270AA of the Act for seeking immunity from imposition of the penalty under Section 270A, therefore, it can safely be concluded that he had dislodged the view taken by the A.O, and concurred with the assessee's contention that its case does not fall within the meaning of misrepresentation or suppression of facts as contemplated in Section 270A(9)(a) of the Act. 16. Be that as it may, we have thoughtfully considered the issue in hand i.e., as to whether or not the A.O. is right in law and facts of the case in imposing penalty on the assessee company under Section 270A of the Act? 15 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 17. Admittedly, it is a matter of fact borne from the record that the A.O. had levied the penalty under Section 270A(9)(a) of the Act, for the reason that the assessee company had raised a claim for deduction of interest expenditure of Rs.2,31,20,034/-. Ostensibly, the A.O. was of the view that the assessee company had diverted its interest-bearing funds for advancing interest-free loans/making investments in its three subsidiary companies, therefore, the corresponding interest expenditure was not allowable as a deduction. We are of the firm conviction that as the assessee company had advanced/invested its interest-bearing funds in its three subsidiary companies, therefore, as observed by the Hon’ble Supreme Court in the case of S.A. Builders Ltd Vs. CIT (2007) 288 ITR 1 (SC) it can safely be concluded that it had done so being guided by the principle of commercial expediency for the furtherance of its business interest, and thus, no disallowance of the interest corresponding to the amounts so invested/advanced in its subsidiaries was called for in its case under Section 36(1)(iii) of the Act. For the sake of clarity, the 16 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 observations of the Hon'ble Apex Courtin its aforesaid judgment are culled out as under: “We agree with the view taken by the Delhi High Court in CIT vs. Dalmia Cement (Bhart) Ltd. (2002) 254 ITR 377 that once it is established that there was nexus between the expenditure and the purpose of the business (which need not necessarily be the business of the assessee itself), the Revenue cannot justifiably claim to put itself in the arm-chair of the businessman or in the position of the board of directors and assume the role to decide how much is reasonable expenditure having regard to the circumstances of the case. No businessman can be compelled to maximize its profit. The income tax authorities must put themselves in the shoes of the assessee and see how a prudent businessman would act. The authorities must not look at the matter from their own view point but that of a prudent businessman. As already stated above, we have to see the transfer of the borrowed funds to a sister concern from the point of view of commercial expediency and not from the point of view whether the amount was advanced for earning profits. We wish to make it clear that it is not our opinion that in every case interest on borrowed loan has to be allowed if the assessee advances it to a sister concern. It all depends on the facts and circumstances of the respective case. For instance, if the Directors of the sister concern utilize the amount advanced to it by the assessee for their personal benefit, obviously it cannot be said that such money was advanced as a measure of commercial expediency. However, money can be said to be advanced to a sister concern for commercial expediency in many other circumstances (which need not be enumerated here). However, where it is obvious that a holding company has a deep interest in its subsidiary, and hence if the holding company advances borrowed money to a subsidiary and the same is used by the subsidiary for some business purposes, the assessee would, in our opinion, ordinarily be entitled to deduction of interest on its borrowed loans.” 18. Apart from that, we find substance in the ld. AR’s contention that merely because the claim for deduction of interest 17 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 expenditure that was raised by the assessee company based on a complete disclosure and correct representation of the facts was not acceptable to the A.O., then, on the said stand-alone basis, penalty under Section 270A of the Act could not have been imposed by him. Rather, as per Section 270A(6)(a) of the Act, the A.O. in the backdrop of the aforesaid bonafide explanation of the assessee company regarding its claim for deduction of interest expenditure that was substantiated by full disclosure of all material facts ought not to have held that there was underreporting of income by the assessee company on the said aspect. Our aforesaid view is fortified based on an analogy that can be safely drawn from the judgment of the Hon'ble Supreme Court in the case of CIT Vs. Reliance Petroproducts Pvt. Ltd., (2010) 322 ITR 158 (SC). The Hon'ble Apex Court, in its order, which though was rendered in the context of Section 271(1)(c) of the Act, had observed that merely because the assessee company before them had claimed a deduction for an expenditure, which however, was not acceptable to the revenue, that by itself would not justify imposing the penalty under the aforesaid statutory provision. Apart from that, we are guided by the judgment of Hon'ble Supreme Court in the case of 18 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 Price Waterhouse Coopers Pvt. Ltd. Vs. CIT and Another (2012) 348 ITR 306 (SC). Once again, the Hon'ble Supreme Court, had in the context of Section 271(1)(c) of the Act, observed that the wrong claim of deduction of provision towards payment of gratuity by the assessee company before them was a result of an inadvertent and bona fide error, which could be brought within the meaning of a “Silly” mistake, but there was no question of either concealment of income or furnishing of inaccurate particulars of income. 20. Based on our aforesaid deliberations, we are of the firm conviction that as the assessee’s claim for deduction of interest expenditure, insofar as the same pertains to interest-free advances/investments made in its three subsidiary companies was based on a bona fide belief that the same was allowable as per the mandate of law, therefore, the AO, as per Section 270A(6) of the Act, considering the bona fide of the assessee company which had come up with full disclosure of all the material facts pertaining to its said claim of deduction in its Computation of 19 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 Income/Financial Statements, ought not to have held that the assessee company had underreported its income. 21. Be that as it may, we are further of the firm conviction that as the company had cumulatively satisfied the set of pre- conditions contemplated in Section 270AA of the Act for seeking immunity from imposition of penalty under Section 270A of the Act, viz. (i). that as the assessee company had uploaded “Form 68” as an attachment along with its online submission of a letter dated 05.05.2021 in response to “Show-Cause Notice”(SCN) issued under Section 274 read with Section 270A of the Act dated 10.04.2021, therefore, in the absence of anything provided in Section 270AA of the Act that the said application was only to be filed with the JAO, it can safely be concluded that it had filed the said application in the prescribed “Form 68” i.e within the stipulated time period; (ii). that as the claim for deduction of interest expenditure by the assessee company pertaining to the interest-free advances/investments made in its three subsidiary companies was based on a bona fide belief that the same was allowable as per the mandate of law, and the assessee company 20 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 had come up with full disclosure of all the material facts pertaining to its said claim of deduction in its Computation of Income/Financial Statements, therefore, the disallowance of its said claim for deduction of interest expenditure could not be brought within the meaning of Section 270A(9)(a) of the Act i.e., underreporting of income in consequence of misrepresentation or suppression of facts’; (iii). that the assessee company had not carried the order of assessment any further in appeal; and (iv). that the assessee company had paid the entire amount of assessed tax liability of Rs. 16,99,960/- on 03.05.2021, therefore, as observed by the CIT(A), and rightly so, the assessee company was as per the mandate of Section 270AA of the Act duly entitled for immunity from imposition of penalty under Section 270A of the Act. 22. We thus, in terms of our aforesaid observations hold a firm conviction that in the backdrop of the facts involved in the present case, the assessee company was not liable to be visited with any penalty under Section 270A(9)(a) of the Act, i.e. underreporting of its income in consequence of misrepresentation or suppression of facts. Alternatively, we concur with CIT(A) that the assessee 21 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 company having satisfied the set of pre-conditions contemplated under Section 270AA of the Act could not have been saddled with the penalty under Section 270A of the Act. 22. Resultantly, we uphold the order passed by the CIT(A) in terms of our aforesaid observations and dismiss the appeal filed by the revenue, while for allow the cross-objection filed by the assessee company. Order pronounced in the Open Court on 28th April, 2025. Sd/- (श्री मिुसूदन सावडिया) (MADHUSUDAN SAWDIA) लेखा सदस्य/ACCOUNTANT MEMBER Sd/- (श्री रवीश सूद) (RAVISH SOOD) न्यायिक सदस्य/JUDICIAL MEMBER Sd/- Hyderabad, dated 28.04.2025. #*TYNM/sps 22 ITA No.28/Hyd/2025 and C.O.No.6/Hyd/2025 आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:- 1. निर्धाररती/The Assessee : NSL Nagapatnam Power Ventures Private Limited, 8-2-684/2/A, 4th Floor, NSL Icon Road no.12, Khairatabad, Banjara Hills, S.O. Hyderabad. 2. रधजस्व/ The Revenue : Income Tax Officer, Ward – 16(1), Hyderabad. 3. The Principal Commissioner of Income Tax, Hyderabad 4. नवभधगीयप्रनतनिनर्, आयकर अपीलीय अनर्करण, हैदरधबधद / DR, ITAT, Hyderabad 5. गधर्ाफ़धईल / Guard file आदेशधिुसधर / BY ORDER Sr. Private Secretary ITAT, Hyderabad "