IDEA CELLULAR LTD, HYD,HYDERABAD vs. ACIT, TDS CIRCLE, WARD-1(1), HYD, HYDERABAD

In the result, both the appeals under consideration are partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

section 206C( a TCS mechanism is TDS provision.) Therefore Assessee humbly submits that with utmost respect to Hon'ble Andhra Pradesh High Court, in view of above facts on accounting and above submissions, a different view may be taken. In so far as recent decision of Hon'ble Hyderabad ITAT in Vodafone Mobile services Vs. DCIT (86 taxmann 115

IDEA CELLULAR LTD, HYD,HYDERABAD vs. ACIT, TDS CIRCLE, WARD-1(1), HYD, HYDERABAD

In the result, both the appeals under consideration are partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

section 206C( a TCS mechanism is TDS provision.) Therefore Assessee humbly submits that with utmost respect to Hon'ble Andhra Pradesh High Court, in view of above facts on accounting and above submissions, a different view may be taken. In so far as recent decision of Hon'ble Hyderabad ITAT in Vodafone Mobile services Vs. DCIT (86 taxmann 115

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

115-0 of the Act at 16.995%. ITA Nos.1613 & 1632/Hyd/2017 Page 6 11. The Ld.AO/ CIT(A) ought to have held that if tax is paid on Dividend paid/ distributed over and above the rate provided in the DTAA, then such excess tax ought to refunded to is the Appellant. Appellant craves leave to consider each of the above grounds

SHARATH KUMAR REDDY SAREDDY,WANAPARTHY, MAHABUB NAGAR. vs. INCOME TAX OFFICER, WARD -1, MAHABUBNAGAR

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1096/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Sharath Kumar Reddy Vs. Income Tax Officer Sareddy, Wanaparthy Ward – 1 Mahbubnagar Mahbubnagar Pan:Hpwps0712H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/07/2025 घोषणा की तारीख/Pronouncement: 20/08/2025 आदेश/Order

TDS effective from 01/04/2023. He has submitted that these 2 provisions specifically govern the taxation of the income from online game. This newly introduced regime replaced the earlier arbitrary framework that provide charging of tax on the gross winning amount without recognizing the loss or entire cost. Section 115BBJ introduced the concept of new net winning which more accurately reflects

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

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

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. DCIT., CIRCLE-13(1), HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

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 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:

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

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.283, 284 & 286/Hyd/2024 (निर्धारण वर्ष/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 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. Cit, Circle 13(1) Hyderabad Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / 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

INCOME TAX OFFICER (INTERNATIONAL TAXATION)-1, HYDERABAD vs. ARUNA GULLAPALLI, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Income Tax Officer, Vs. Aruna Gullapalli, (International Taxation) – 1, Hyderabad. Hyderabad. Pan No.Bfhpg9489L. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Kumar Adithya Date Of Hearing: 23.01.2023 Date Of Pronouncement: 31.01.2023

TDS u/s 194IA. 12.1 Thus, the appellant has factually demonstrated, that the entire sale consideration received on sale of plot was reinvested in a residential property, though the legal formalities of getting the property in the appellant’s name did not take place within the time stipulated u/s 54F. Here arises a legal complication. 12.2 The heading of section

ITO (INTERNATIONAL TAXATION)-1, HYDERAABAD vs. DEENABABU KONDUBHATLA, HYDERABAD

Bench: Us :

TDS relating to Section 195. 3 3. During the course of assessment proceedings, the A.O. observed that the assessee had, during the subject year, sold two immovable properties, on which Long Term Capital Gain aggregating to Rs. 13,18,002/-, viz. (i). Property - I: Rs. 55,887/- and (ii). Property – II: Rs.12,62,115

INCOME TAX OFFICER, WARD-2(1) , HYDERABAD vs. GAIAN SOLUTIONS INDIA PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is dismissed

Bench: Smt. P. Madhavi Devi

115 JB of the Act. During assessment proceedings u/s 143(3) of the Act, the assessee was required to submit various details. However, since the assessee did not respond, the AO completed the assessment u/s 144 of the Act by treating a sum of Rs.12,88,022/- as unexplained investments u/s 69C of the Act and also by disallowing foreign

ADP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is partly allowed

Bench: Shri Manjunatha G & Shri Ravish Sood

115/- and 4 ITA.No.975/Hyd./2024 charged interest u/sec.234A and 234C of the Income Tax Act, 1961. [ 4. Aggrieved by the Final Assessment Order, the appellant-company is now, in appeal before the Tribunal. 5. Grounds of appeal Nos.1 and 2 of assessee’s appeal are general in nature and does not require specific adjudication and, therefore, grounds of appeal

MADDIRALA SRINIVASA RAO,HYDERABAD vs. ACIT., CENTRAL CIRCLE 3(1), HYDERABAD

In the result, both the appeals filed by the assessee, i

TDS) on the said receipts from printing work was deducted under section 194C @1%. Accordingly, the assessee in his original return of income that was filed on 04/09/2020, i.e., prior to the date of search conducted on 21/11/2020, disclosed an income aggregating to Rs.9,84,191/- (viz., income from designing: Rs.6,92,038/- (i.e., 50% of gross receipts of Rs.13

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

TDS which is compensatory in nature and is not expense which is prohibited by law or with respect to any offence. Hence, we hereby direct the ld. AO to delete the addition made for Rs. 1,07,898/-. Appeal No.959/H/2014 (AY: 2006-07): (Revenue’s appeal) 77. Ground no.:(i) Deletion of the addition made

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

TDS which is compensatory in nature and is not expense which is prohibited by law or with respect to any offence. Hence, we hereby direct the ld. AO to delete the addition made for Rs. 1,07,898/-. Appeal No.959/H/2014 (AY: 2006-07): (Revenue’s appeal) 77. Ground no.:(i) Deletion of the addition made

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

TDS which is compensatory in nature and is not expense which is prohibited by law or with respect to any offence. Hence, we hereby direct the ld. AO to delete the addition made for Rs. 1,07,898/-. Appeal No.959/H/2014 (AY: 2006-07): (Revenue’s appeal) 77. Ground no.:(i) Deletion of the addition made