BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10,00,000/- shown as cash payment for purchase of new vehicles. Even though the above expenditure is capital in nature, the A.O. made addition u/s 69C of the Act. Therefore, he submitted that, the addition made by the A.O. should be deleted. 29. The Learned Senior A.R. for the Revenue, on the other hand, supporting the order

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

10,00,000/- shown as cash payment for purchase of new vehicles. Even though the above expenditure is capital in nature, the A.O. made addition u/s 69C of the Act. Therefore, he submitted that, the addition made by the A.O. should be deleted. 29. The Learned Senior A.R. for the Revenue, on the other hand, supporting the order

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

TDS was applicable on the same. However, in the present facts of the Appellant, the issue is not whether the payment for obtaining licenses of software and software maintenance would be royalty or not and whether there would be any tax required to be deducted at source. The issue here is whether the expenditure incurred would be revenue or capital

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

In the result, appeal filed by the assessee is allowed

10(34) of the I.T. Act, 1961. Therefore, the disallowance to the extent of these investments in the foreign subsidiaries cannot be made u/s 14A of the I.T. Act, 1961. The only investment in the Indian company is made by the assessee in the preceding year and not during the year under consideration and therefore, when there is no dividend

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

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

TDS (vi) Provision For sales 24,37,666 24,37,666 commission (vii) Donation 1,600 3.Disallowance u/s 27,150 27,150 27,150 40A(3) 4. Disallowance u/s 53,49,466 87,79,789 34,30,323 43B 5. Disallowable u/s 57,600 57,600 57,600 40(a)(ia) 6. Disallowance

ANALOGICS TECH INDIA LIMITED ,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed

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

34 of 1948) or any other fund for the welfare of the employees. It, therefore, goes without saying that this deemed income has to be treated as the income of the assessee, the moment such an amount comes to the possession of the assessee. It is open for the assessee to claim deduction of the same under section

CYIENT LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2021-22 Cyient Limited, Vs. The Deputy Commissioner Of Income Tax, Circle 1 (1), Hyderabad. Hyderabad. Apn : Aaac14887J

34(a) under TDS provisions, the assessee has admitted to have deducted TDS on salaries and wages of Rs.5,01,23,59,279/-. Since there is a difference of 8 Rs.1,28,52,83,944/-, the Assessing Officer called upon the assessee to file necessary evidences and also explain why TDS has not been deducted. Since the assessee

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

ASST. COMMISSIONER OF INCOME TAX CIRCLE-1,, KHAMMAM vs. M/S SINGARENI COLLERIES COMPANY LTD.,, KHAMMAM DIST

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

ASST. COMMISSIONER OF INCOME TAX CIRCLE-1,, KHAMMAM vs. M/S SINGARENI COLLERIES COMPANY LTD.,, KHAMMAM DIST

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

DCIT, CIRCLE-1, KHAMMAM, KHAMMAM vs. THE SINGARENI COLLERIES COMPANY LT.D, KOTHAGUDEM, KOTHAGUDEM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

THE SINGARENI COLLERIES COMPANY LTD., KOTHJAGUDEM,HYDERABAD vs. ADDL.CITT, KHAMMAM RANGE, KHAMMAM, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

ASST. COMMISSIONER OF INCOME TAX CIRCLE-1,, KHAMMAM vs. M/S SINGARENI COLLERIES COMPANY LTD.,, KHAMMAM DIST

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

TDS amount to the Central Government and deposits only the balance amount with the Court, in view of the aforesaid ruling, the Court may not hold it as disobedience of its orders. 9.6 Later on the Board has also issued a Circular a CIRCULAR NO. 8/2011 [F.NO. 275/30/2011- IT (B)], DATED 14-10-2011 [SUPERSEDED BY CIRCULAR NO. 23/2015, DATED

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. IL & FS ENGINEERING & CONSTRUCTIONS CO. LIMITED , HYDERABAD

34,21,819/-. The appellant explained that vehicle hire\ncharges, which are covered u/s 194C of the Act, reported in this\nAnnexure. These transactions relate to engaging vehicles at the\nsite on one time basis and TDS is not deducted on these\ntransactions due to lack of knowledge of the accountants.\nSimilarly, in respect of other transactions, TDS

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

34 (SC)) and ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd. [(2007) 291 ITR 500 (SC)]. Further, the approval under section 151 was duly obtained and the reasons for reopening were recorded, as confirmed in the assessment order. The reassessment was within the prescribed time and squarely falls within the framework of section 147, Therefore, the action