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:

TDS? Accordingly, we have heard Advocate Parchure for the Department Advocate Dewani for assessee. We find that the provision for educational facilities is being made by assessee as a part of its obligation under various National Coal Wage Agreement (NCWA), which are legally enforceable in terms of Section 18 of the Industrial Dispute Act. The said provision is also accepted

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:

TDS? Accordingly, we have heard Advocate Parchure for the Department Advocate Dewani for assessee. We find that the provision for educational facilities is being made by assessee as a part of its obligation under various National Coal Wage Agreement (NCWA), which are legally enforceable in terms of Section 18 of the Industrial Dispute Act. The said provision is also accepted

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:

TDS? Accordingly, we have heard Advocate Parchure for the Department Advocate Dewani for assessee. We find that the provision for educational facilities is being made by assessee as a part of its obligation under various National Coal Wage Agreement (NCWA), which are legally enforceable in terms of Section 18 of the Industrial Dispute Act. The said provision is also accepted

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

TDS?\nAccordingly, we have heard Advocate Parchure for the\nDepartment Advocate Dewani for assessee. We find that the\nprovision for educational facilities is being made by assessee\nas a part of its obligation under various National Coal Wage\nAgreement (NCWA), which are legally enforceable in terms\nof Section 18 of the Industrial Dispute Act. The said\nprovision is also accepted

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

In the result, assessee's appeals for the A

TDS?\nAccordingly, we have heard Advocate Parchure for the\nDepartment Advocate Dewani for assessee. We find that the\nprovision for educational facilities is being made by assessee\nas a part of its obligation under various National Coal Wage\nAgreement (NCWA), which are legally enforceable in terms\nof Section 18 of the Industrial Dispute Act. The said\nprovision is also accepted

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

TDS to the tune of Rs. 30,211/- without assigning any reasons therefor. 10. The appellant craves leave to add, amend or alter any of the grounds during the course of hearing.” 2. Brief facts of the case are that the assessee-company is engaged in manufacturing of Clinker and Ordinary Portland Cement. The assessee, being the third largest cement

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

10B or section 10BA or under any provision of this chapter under the heading "C-D Deductions in respect of certain incomes”, no deductions shall be allowed to him there under”. 5 Tracks & Towers Infratech Pvt.Ltd. (Part IX) 80AC: “Where in computing the total income of an assessee of the previous year relevant to the assessment year commencing

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

10B or section 10BA or under any provision of this chapter under the heading "C-D Deductions in respect of certain incomes”, no deductions shall be allowed to him there under”. 5 Tracks & Towers Infratech Pvt.Ltd. (Part IX) 80AC: “Where in computing the total income of an assessee of the previous year relevant to the assessment year commencing

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

8 October 2013 and enclosed as Page 114 to 1 1 6 of the factual paper Book. 12. The Ld. AO has considered the payment for purchase of software and software maintenance as purchases in the nature of profit earning apparatus or enhancement of such apparatus because they are used in server virtualization and cloud computing and therefore, the purchases

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

8, it is clear that it has approved the ratio laid\ndown by the Delhi High Court in the case of Kabul\nChawla (supra) and the Gujarat High Court in the case of\nPCIT Vs. Saumya Constructions reported in (2016) 387\nITR 529 (Guj) and the Hon'ble High Court of Rajasthan\nhas followed or considered the ratio of these

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

DCIT,CENTRAL CIRCLE - 7, HYDERABAD vs. M/S MIDWEST GRANITE PRIVATE LIMITED., HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

DCIT,CENTRAL CIRCLE - 7, HYDERABAD vs. M/S MIDWEST GRANITE PRIVATE LIMITED., HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

10B are not available which creates a doubt that the assessee has been claiming bogus expenditure in order to avoid tax liability. (v) Filing of return of income by including such bogus receipts and paying tax thereon alone cannot establish the genuineness of the transaction. 21. Having observed so, the Ld. CIT (A) further opined that activities such as cutting