PROGRESSIVE CONSTRUCTIONS LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.625/Hyd/2025 Assessment Year 2021-2022 Progressive Constructions The Dcit, Limited, Hyderabad. Circle-5(1) Vs. Pin – 500 001. Telangana. Hyderabad - 500 004. Pan Aabcp2274M Telangana. (Appellant) (Respondent) Ca Pawan Kumar Chakrapani िनधा"रती "ारा/Assessee By : & Sri Santi Pavan Kumar, Advocate राज" व "ारा/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 02.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

section 263 of the Act, under the facts and circumstances of the case. 7. The Honorable Pr. CIT ought to have appreciated the fact that, the claim of bad debts are allowable as the amount of Rs.141,66,01,735/-, is taken into account in computing the income of the Appellant of the previous years, under the facts and circumstances

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:

2 of that D.O. letter, it was stated that while paying interest, income-tax was deductible at the rates in force during that financial year with effect from 1-4- 1975, if the amount exceeded Rs. 1,000. Pursuant to those instructions, the Land Acquisition Officers, while depositing the enhanced compensation amounts in various execution petitions filed before the Subordinate

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:

2 of that D.O. letter, it was stated that while paying interest, income-tax was deductible at the rates in force during that financial year with effect from 1-4- 1975, if the amount exceeded Rs. 1,000. Pursuant to those instructions, the Land Acquisition Officers, while depositing the enhanced compensation amounts in various execution petitions filed before the Subordinate

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:

2 of that D.O. letter, it was stated that while paying interest, income-tax was deductible at the rates in force during that financial year with effect from 1-4- 1975, if the amount exceeded Rs. 1,000. Pursuant to those instructions, the Land Acquisition Officers, while depositing the enhanced compensation amounts in various execution petitions filed before the Subordinate

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:

2 of that D.O. letter, it was stated that while paying interest, income-tax was deductible at the rates in force during that financial year with effect from 1-4- 1975, if the amount exceeded Rs. 1,000. Pursuant to those instructions, the Land Acquisition Officers, while depositing the enhanced compensation amounts in various execution petitions filed before the Subordinate

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

section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest, income-tax was deductible at the\nrates in force during that financial year with effect from 1-4-\n1975, if the amount exceeded Rs.1,000.\nPursuant to those instructions, the Land Acquisition\nOfficers, while depositing the enhanced compensation

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

In the result, assessee's appeals for the A

section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest, income-tax was deductible at the\nrates in force during that financial year with effect from 1-4-\n1975, if the amount exceeded Rs.1,000.\nPursuant to those instructions, the Land Acquisition\nOfficers, while depositing the enhanced compensation

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

TDS, without appreciating fact that, the payments are not taxable in India under the provisions of respective tax treaties. 7.2. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in not appreciating the fact that, by applying most favoured nation clause as contained in India Netherlands tax treaty and by accessing India-Finland

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

TDS, without appreciating fact that, the payments are not taxable in India under the provisions of respective tax treaties. 7.2. That on the facts and circumstances of the case and in law, the Ld. AO/DRP erred in not appreciating the fact that, by applying most favoured nation clause as contained in India Netherlands tax treaty and by accessing India-Finland

ELITE INFRAPROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

TDS credit claimed in the return of income is incorrect. The credit for the tax deducted at source was only claimed to the extent it is appearing in Form 26AS. For the services provided by the company during the year, the recipients of services have paid the amounts to the assessee after deducting tax at source in accordance with

ELITE INFRAPROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

TDS credit claimed in the return of income is incorrect. The credit for the tax deducted at source was only claimed to the extent it is appearing in Form 26AS. For the services provided by the company during the year, the recipients of services have paid the amounts to the assessee after deducting tax at source in accordance with

ELITE INFRAPROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

TDS credit claimed in the return of income is incorrect. The credit for the tax deducted at source was only claimed to the extent it is appearing in Form 26AS. For the services provided by the company during the year, the recipients of services have paid the amounts to the assessee after deducting tax at source in accordance with

ELITE INFRAPROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

TDS credit claimed in the return of income is incorrect. The credit for the tax deducted at source was only claimed to the extent it is appearing in Form 26AS. For the services provided by the company during the year, the recipients of services have paid the amounts to the assessee after deducting tax at source in accordance with

ELITE INFRAPROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

TDS credit claimed in the return of income is incorrect. The credit for the tax deducted at source was only claimed to the extent it is appearing in Form 26AS. For the services provided by the company during the year, the recipients of services have paid the amounts to the assessee after deducting tax at source in accordance with

ELITE INFRAPROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

TDS credit claimed in the return of income is incorrect. The credit for the tax deducted at source was only claimed to the extent it is appearing in Form 26AS. For the services provided by the company during the year, the recipients of services have paid the amounts to the assessee after deducting tax at source in accordance with

ELITE INFRAPROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

TDS credit claimed in the return of income is incorrect. The credit for the tax deducted at source was only claimed to the extent it is appearing in Form 26AS. For the services provided by the company during the year, the recipients of services have paid the amounts to the assessee after deducting tax at source in accordance with

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

TDS on ESOP is an international transaction with its AE which was not at arm's length. 4:2 The Appellant submits that considering the facts and circumstances of its case and the law prevailing on the subject the international transactions relating to recovery of expenses were at arm's length and hence no adjustment in respect thereof was called

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

TDS on ESOP is an international transaction with its AE which was not at arm's length. 4:2 The Appellant submits that considering the facts and circumstances of its case and the law prevailing on the subject the international transactions relating to recovery of expenses were at arm's length and hence no adjustment in respect thereof was called