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

section 80IA(5) only requires filing of return of income but nowhere it states that the claim should be made in the original return and not by way of revised return. It has been held that when the original return was filed within the due date, then the revised return filed, thereafter, before the completion of the assessment proceedings

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

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

5) of the Act on 01.07.2020 when such claim was not made in the original return of income filed under Section 139(1) of the Act on 30.10.2019. Since the assessee has not satisfied the conditions provided under Section 80A read with Section 80AC of the Act, and also as per the provisions of Section

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

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

5) of the Act on 01.07.2020 when such claim was not made in the original return of income filed under Section 139(1) of the Act on 30.10.2019. Since the assessee has not satisfied the conditions provided under Section 80A read with Section 80AC of the Act, and also as per the provisions of Section

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

139 of the Act and thus, all\nthe conditions prescribed under Section 80A(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

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

139 of the Act and thus, all\nthe conditions prescribed under Section 80A(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

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

In the result appeals filed by the Revenue\nITA

139 of the Act and thus, all\nthe conditions prescribed under Section 80A(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

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

139 of the Act and thus, all\nthe conditions prescribed under Section 80A(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

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:

139(1), as a check has been put in place by virtue of section 10B (5) to verify the correctness of claim of deduction at the time of filing the return. If an assessee claims an exemption under the Act by virtue of Section 10B, then the correctness of claim has already been verified under section 10B (5). Therefore

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:

139(1), as a check has been put in place by virtue of section 10B (5) to verify the correctness of claim of deduction at the time of filing the return. If an assessee claims an exemption under the Act by virtue of Section 10B, then the correctness of claim has already been verified under section 10B (5). Therefore

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:

139(1), as a check has been put in place by virtue of section 10B (5) to verify the correctness of claim of deduction at the time of filing the return. If an assessee claims an exemption under the Act by virtue of Section 10B, then the correctness of claim has already been verified under section 10B (5). Therefore

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:

139(1), as a check has been put in place by virtue of section 10B (5) to verify the correctness of claim of deduction at the time of filing the return. If an assessee claims an exemption under the Act by virtue of Section 10B, then the correctness of claim has already been verified under section 10B (5). Therefore

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

section 139(1) of the Act, i.e., up to the “due date” of 31/10/2013, disallowed its claim for carry forward loss of Rs. 27,58,236/-. 5. The AO observed that the information available on record revealed that the assessee company had contractual receipts of Rs. 3,20,42,152/- on which tax was deducted at source (TDS

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

139(1), as a\ncheck has been put in place by virtue of section 10B (5) to\nverify the correctness of claim of deduction at the time of\nfiling the return. If an assessee claims an exemption under\nthe Act by virtue of Section 10B, then the correctness of claim\nhas already been verified under section 10B (5). Therefore

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

In the result, assessee's appeals for the A

139(1), as a\ncheck has been put in place by virtue of section 10B (5) to\nverify the correctness of claim of deduction at the time of\nfiling the return. If an assessee claims an exemption under\nthe Act by virtue of Section 10B, then the correctness of claim\nhas already been verified under section 10B (5). Therefore

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

sections of the Act under any five heads of income. 15. The Ld. CIT(A) erred in initiating the penalty proceedings u/s 271(1)(c) against concealment of income without appreciating the facts. 16. The Ld. CIT (A) has erred in charging interest u/s 234A, 234B and 234C of the Act basing on the income determined in the assessment proceedings

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

sections of the Act under any five heads of income. 15. The Ld. CIT(A) erred in initiating the penalty proceedings u/s 271(1)(c) against concealment of income without appreciating the facts. 16. The Ld. CIT (A) has erred in charging interest u/s 234A, 234B and 234C of the Act basing on the income determined in the assessment proceedings

ORBIT VENTURES,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

sections of the Act under any five heads of income. 15. The Ld. CIT(A) erred in initiating the penalty proceedings u/s 271(1)(c) against concealment of income without appreciating the facts. 16. The Ld. CIT (A) has erred in charging interest u/s 234A, 234B and 234C of the Act basing on the income determined in the assessment proceedings

ORBIT VENTURES,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

sections of the Act under any five heads of income. 15. The Ld. CIT(A) erred in initiating the penalty proceedings u/s 271(1)(c) against concealment of income without appreciating the facts. 16. The Ld. CIT (A) has erred in charging interest u/s 234A, 234B and 234C of the Act basing on the income determined in the assessment proceedings

ORBIT VENTURES,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

sections of the Act under any five heads of income. 15. The Ld. CIT(A) erred in initiating the penalty proceedings u/s 271(1)(c) against concealment of income without appreciating the facts. 16. The Ld. CIT (A) has erred in charging interest u/s 234A, 234B and 234C of the Act basing on the income determined in the assessment proceedings