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2024 Supreme(Online)(ITAT) 3735

INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Shri Laliat Kumar, J, Shri Manjunatha G, ACJ
SARAT GOPAL BOPPANA HYDERABAD – Appellant
Versus
ACIT. CENTRAL CIRCLE-2(3) HYDERABAD – Respondent


Advocates:
For the Appellants/Petitioners: P. Murali Mohan Rao
For the Respondents: Jeevan Lal Lavidia

Table of Content
1. introduction to facts of the case and context of appeals. (Para 1 , 4 , 10)
2. common grounds of appeal raised by assessee and revenue. (Para 2 , 3)
3. court's assessment of the income tax provisions and agreement details. (Para 5 , 6 , 11)
4. counsel's arguments regarding the principles of compensation. (Para 12 , 14)
5. court's observations on the agreement terms and compensation arguments. (Para 13 , 15)
6. final order on the appeals and dismissals. (Para 16)
7. summary of dismissal of revenue's appeals. (Para 17 , 20 , 21)

ORDER

PER BENCH :

This bunch of eight appeals, four by different assessee’s and four by the Revenue, are directed against separate, but identical orders of the Commissioner of Income Tax (Appeals) – 12, Hyderabad all dated 20.09.2022 and pertains to A.Y. 2016-17. Since facts are identical and issues are common, for the sake of convenience, these appeals filed by the assessee’s and, as well as the Revenue are being heard together and are being disposed off, by this consolidated order.

2. The assessee’s have more or less filed common grounds of appeal in their respective grounds of appeals and therefore, for the sake of brevity, the grounds of appeal f

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