GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

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

13) of the Act passed by Assessment Unit, Income-tax Department, pursuant to invalid directions passed by Hon'ble DRP, is illegal; thus making the final assessment order bad in law, null and void and so liable to be quashed. Grounds relating to Transfer Pricing ("TP") 3. On the facts and in the circumstances of the case

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

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. 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

KAVERI POLYMERS,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

c) of sub- section (1) of this section, be deemed to have concealed the particulars of his income or furnished inaccurate particulars of such income.] 13. In the present case, search has taken place in the premises of assessee on 09.08.2018 and in the search, the assessee had declared the income in the return of income filed after the date

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

13. In the present case, the assessee had filed the return of income for the A.Y. 2016-17 on 03.10.2016 admitting the total income of Rs.6,28,00,980/-. However, the assessee while filing the return of income in pursuance to the notice u/s. 153A had admitted the total income of Rs.8,35,03,680/-. In other words, the assessee

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE-1(3),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

13. In the present case, the assessee had filed the return of income for the A.Y. 2016-17 on 03.10.2016 admitting the total income of Rs.6,28,00,980/-. However, the assessee while filing the return of income in pursuance to the notice u/s. 153A had admitted the total income of Rs.8,35,03,680/-. In other words, the assessee

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

TDS credit amounting to INR 6,360 appearing in the Form 26AS as per the\nOGE dated 07 February 2024 pursuant to the order of Hon'ble CIT(A).\n19. erred in levying interest under section 234C of the Act in the impugned order.\n20. erred in initiating penalty proceedings under section 270A of the Act against the Appellant without

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

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

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

13) read with section 144B of the Act, dated 06 December 2024 is illegal and void in as much as it is barred by limitation as the order is passed beyond the time limit prescribed under section 153 of the Act and therefore the order, is liable to be set aside. Grounds relating to corporate tax: 2. Ground 2: Erroneous

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

13(1)\nHyderabad\n(Appellant)\nSingareni Collieries\nCompany Limited\nKothagudem\nPAN:AAACT8873F\n(Respondent)\nनिर्धारिती द्वारा / Assessee by: Shri M.V.Anil Kumar, Advocate\nराजस्व द्वारा / Revenue by:: Shri B Balakrishna, CIT (DR)\nसुनवाई की तारीख / Date of hearing: 10/06/2025\nघोषणा की तारीख / Pronouncement: 12/06/2025\nआदेश/ORDER\nPer Bench:\nThese 3 sets of cross appeals filed by the assessee as\nwell

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is partly allowed

C) No. 593/08), submitted that the assessee had debited a sum of Rs. 41,06,748.00 to its P&L account of which a sum of Rs. 29,49,088.00 stood for the unrealized loss due to foreign exchange fluctuation. According to the learned counsel, the assessee has been following mercantile system of accounting. According to the learned counsel, under

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

In the result, assessee's appeals for the A

13(1)\nHyderabad\nSingareni Collieries\nCompany Limited\nKothagudem\nPAN:AAACT8873F\n(Appellant)\n(Respondent)\nनिर्धारिती द्वारा / Assessee by: Shri M.V.Anil Kumar, Advocate\nराजस्व द्वारा / Revenue by:: Shri B Balakrishna, CIT (DR)\nसुनवाई की तारीख / Date of hearing: 10/06/2025\nघोषणा की तारीख / Pronouncement: 12/06/2025\nआदेश/ORDER\nPer Bench:\nThese 3 sets of cross appeals filed by the assessee as\nwell

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

c, in my opinion, as it qualifies the condition mentioned under section 80IA(4), it is entitled for deduction under section 80IA of the Act. The AO is directed to allow the claim of section 80IA after proper verification." Considering the above facts and the settled position of law, we are of the opinion that the order

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

c, in my opinion, as it qualifies the condition mentioned under section 80IA(4), it is entitled for deduction under section 80IA of the Act. The AO is directed to allow the claim of section 80IA after proper verification." Considering the above facts and the settled position of law, we are of the opinion that the order

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the appeals of the assessee for the\nA

section 148 of the\nIncome Tax Act, 1961\nImproper many\nis covered w/1149(1)(b).\nIsame of motive of/5148\nis ayyun.\nDate: 6/10/23\n(SANJAY BAHADUR, IRS)\nDirector General of Income Tax (Inv).\nHyderabad.\n5.\nThus, it is clear that an identical sanction was granted\nby the DGIT (Inv), Hyderabad for all the A.Ys.\n6.\nAt the outset, we note

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. ACIT.,CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the appeals of the assessee for the\nA

section 148 of the\nIncome Tax Act, 1961\n(YOGESH KUMAR VERMA, IRS)\nPrincipal Commissioner of Income Tax (Central),\nHyderabad.\nDate: 6/10/23\n(SANJAY BAHADUR, IRS)\nDirector General of Income Tax (Inv).\nHyderabad.\n5. Thus, it is clear that an identical sanction was granted by the DGIT (Inv), Hyderabad for all the A.Ys.\n6. At the outset, we note that

EXEL RUBBER PRIVATE LIMITED,K.V.RANGAREDDY vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the appeals of the assessee for the\nA

Section 148 is bad in law.\n8. On the facts and circumstance of the case, Learned CIT(A)\nis not justified in sustaining the addition of Rs.46,06,858/ -.\n9. Any other ground or grounds that may be urged at the\ntime of hearing of the appeal.”\n\n3.\nWe have considered the rival contentions as well as the\nrelevant