DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

10. In the case of the assessee, it had filed a revised return on 30.3.2010 which is before expiry of one year from the relevant assessment year and therefore the return filed is a valid return as per the provisions section 139(5), as the original return was filed under section 139(1) within due date prescribed. In fact

PRASANTH NANDANURU,HYDERABAD vs. ITO, (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal of the assessee is allowed

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

section 5(2)(a) of the Act but not by 5(2)(b) of the Act. In respect of Article 16(1) of DTAA, learned DR submitted that such an article is not applicable to the case of the assessee, Page 4 of 11 ITA-IT No. 369/Hyd/2022 because, the assessee was exercising the employment pursuant to the contract with

PATEL SEW JOINT VENTURE,TELANGANA vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, the cross-objection filed by the assessee is dismissed

10. If we read the provisions of Section 80A read with Section 80AC of the Act, along with the decision of the Hon'ble Supreme Court in the case of Pr. CIT Vs. Wipro Ltd. (supra), the claim made by the assessee towards deduction under Section 80-IA(4) of the Act, in the revised return filed under Section

ACIT., CIRCLE-6(1), HYDERABAD vs. PATEL SEW JOINTVENTURE, HYDERABAD

In the result, the cross-objection filed by the assessee is dismissed

10. If we read the provisions of Section 80A read with Section 80AC of the Act, along with the decision of the Hon'ble Supreme Court in the case of Pr. CIT Vs. Wipro Ltd. (supra), the claim made by the assessee towards deduction under Section 80-IA(4) of the Act, in the revised return filed under Section

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

5) and Section\n80AC are satisfied is contrary to law and devoid of merit\nand cannot be accepted.\n32.\nIn this view of the matter and considering the\nfacts and circumstances of the case, we are of the\nconsidered view that the assessee cannot make a fresh\nclaim of deduction under Chapter VI-A of the Income Tax\nAct

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

5) and Section\n80AC are satisfied is contrary to law and devoid of merit\nand cannot be accepted.\n32.\nIn this view of the matter and considering the\nfacts and circumstances of the case, we are of the\nconsidered view that the assessee cannot make a fresh\nclaim of deduction under Chapter VI-A of the Income Tax\nAct

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

In the result appeals filed by the Revenue\nITA

5) and Section\n80AC are satisfied is contrary to law and devoid of merit\nand cannot be accepted.\n32.\nIn this view of the matter and considering the\nfacts and circumstances of the case, we are of the\nconsidered view that the assessee cannot make a fresh\nclaim of deduction under Chapter VI-A of the Income Tax\nAct

DY.COMMISSIONER OF INCOME TAX, CIRCLE 2(2), HYDERBAD vs. SEW INFRASTUCTURE LIMITED, HYDERABAD

5) and Section\n80AC are satisfied is contrary to law and devoid of merit\nand cannot be accepted.\n\n32.\nIn this view of the matter and considering the\nfacts and circumstances of the case, we are of the\nconsidered view that the assessee cannot make a fresh\nclaim of deduction under Chapter VI-A of the Income Tax\nAct

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)

TDS under Section 40(a)(ia) of the Act separately. Therefore, once again making additions on the basis of seized documents is incorrect. Since the assessee is able to reconcile the difference by filing relevant evidence, in our considered view, the additions made by the A.O. on the basis of provisional financial statements cannot be upheld. Therefore, we direct

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)

TDS under Section 40(a)(ia) of the Act separately. Therefore, once again making additions on the basis of seized documents is incorrect. Since the assessee is able to reconcile the difference by filing relevant evidence, in our considered view, the additions made by the A.O. on the basis of provisional financial statements cannot be upheld. Therefore, we direct

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)

TDS under Section 40(a)(ia) of the Act separately. Therefore, once again making additions on the basis of seized documents is incorrect. Since the assessee is able to reconcile the difference by filing relevant evidence, in our considered view, the additions made by the A.O. on the basis of provisional financial statements cannot be upheld. Therefore, we direct

DCIT, CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LIMITED, KOTHAGUDEM

10. A settlement\nwithin the meaning of sub-section (3) of Section 18 of the\nIndustrial Disputes Act is binding on both the parties and\ncontinues to remain in force unless the same is altered,\nmodified or substituted by another settlement......\".\n12. A similar issue came up for consideration before the\nJharkhand High Court at Ranchi in L.P.A.No

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE-1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10. A settlement within the meaning of sub-section (3) of Section 18 of the Industrial Disputes Act is binding on both the parties and continues to remain in force unless the same is altered, modified or substituted by another settlement......". 12. A similar issue came up for consideration before the Jharkhand High Court at Ranchi in L.P.A.No

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE- 1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10. A settlement within the meaning of sub-section (3) of Section 18 of the Industrial Disputes Act is binding on both the parties and continues to remain in force unless the same is altered, modified or substituted by another settlement......". 12. A similar issue came up for consideration before the Jharkhand High Court at Ranchi in L.P.A.No

DCIT., CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LTD, KOTHAGUDEM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10. A settlement within the meaning of sub-section (3) of Section 18 of the Industrial Disputes Act is binding on both the parties and continues to remain in force unless the same is altered, modified or substituted by another settlement......". 12. A similar issue came up for consideration before the Jharkhand High Court at Ranchi in L.P.A.No

DCIT., CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LIMITED, KOTHAGUDEM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10. A settlement within the meaning of sub-section (3) of Section 18 of the Industrial Disputes Act is binding on both the parties and continues to remain in force unless the same is altered, modified or substituted by another settlement......". 12. A similar issue came up for consideration before the Jharkhand High Court at Ranchi in L.P.A.No

DEPUTY COMMISSIONER OF INCOME TAX(IT)-II, HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, SECUNDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.725/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2015-16) Dy. C.I.T (It)-Ii Vs. Sew Infrastructure Ltd Hyderabad Secunderabad Pan:Aadcs4061P (Appellant) (Respondent) राज" व "ारा/Revenue By: Shri B Bala Krishna, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate सुनवाई की तारीख/Date Of Hearing: 22/10/2024 घोषणा की तारीख/Pronouncement: 28/10/2024 आदेश/Order

10% tax as per DTAA Page 5 of 8 ITA No 725 of 2024 SEW Infrastructure Ltd between India and Singapore. The Assessing Officer invoked the provisions of section 206AA and computed short deduction of TDS

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. DCIT., CIRCLE-13(1), HYDERABAD

In the result, assessee's appeals for the A

10. A settlement\nwithin the meaning of sub-section (3) of Section 18 of the\nIndustrial Disputes Act is binding on both the parties and\ncontinues to remain in force unless the same is altered,\nmodified or substituted by another settlement......\".\n12. A similar issue came up for consideration before the\nJharkhand High Court at Ranchi in L.P.A.No