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 deduction on the interest payment on compensation/enhanced compensation which is as under: “18/05/2021 Circular No. 526, dated 05-12-1988 1055. Whether interest payments under Land Acquisition Act are covered by section on 194A According to section 194A of the Income-tax Act, 1961, any person, not being an individual or HUF, who is responsible for paying

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 deduction on the interest payment on compensation/enhanced compensation which is as under: “18/05/2021 Circular No. 526, dated 05-12-1988 1055. Whether interest payments under Land Acquisition Act are covered by section on 194A According to section 194A of the Income-tax Act, 1961, any person, not being an individual or HUF, who is responsible for paying

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 deduction on the interest payment on compensation/enhanced compensation which is as under: “18/05/2021 Circular No. 526, dated 05-12-1988 1055. Whether interest payments under Land Acquisition Act are covered by section on 194A According to section 194A of the Income-tax Act, 1961, any person, not being an individual or HUF, who is responsible for paying

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

1-3-1987 to the then Revenue\nSecretary requesting him to issue instructions to all the\nofficers concerned with land acquisition to deduct income-\ntax on payment of interest and to follow the provisions as\nlain down under section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest

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

In the result, assessee's appeals for the A

1-3-1987 to the then Revenue\nSecretary requesting him to issue instructions to all the\nofficers concerned with land acquisition to deduct income-\ntax on payment of interest and to follow the provisions as\nlaid down under section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest

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

Bench: Us:

TDS) under section 194A of the Act. As the assessee company had not filed its return of income for the subject year under section 139(1

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. IL & FS ENGINEERING & CONSTRUCTIONS CO. LIMITED , HYDERABAD

sections": [ "40A(3)", "40(a)(ia)", "194A", "194C", "69C", "36(1)(iii)", "194I" ], "issues": "The main issues involved the validity of disallowances made by the AO and sustained or partly deleted by the CIT(A) concerning cash payments, TDS

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERBAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

TDS) under section 194A of the Act, but had not filed its return of income, initiated penalty proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 29/03/2021 was served upon the assessee company. However, the assessee company failed to file its return of income in compliance to the aforesaid notice. Also, the notices issued

IL & FS ENGINEERING AND CONSTRUCTION COMPANY LIMITED(FORMERLY MAYTAS INFRA LIMITED),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-9, HYDERABAD

TDS non-deduction, disallowance of interest on term loans and subcontractors, and disallowance of vehicle hire charges and other payments were decided. The Tribunal deleted certain additions while confirming others.", "result": "Partly Allowed", "sections": [ "40A(3)", "40(a)(ia)", "194C", "69C", "36(1)(iii)", "194A

SUKESINI KUMILI,HYDERABAD vs. ITO, WARD-15(1), HYDERABAD

TDS Statement Interest other than interest on securities (Section 194A) ANDHRA\nBANK, SITAPHALMANDI BR. 5 AMOUNT PAID OR CREDITED 31,890\n7.\n3. On the basis of above information, which reveals that the income chargeable to tax,\nrepresented in the form of asset, which has escaped assessment amount to the tune of\nRupees more than 50 lakhs, for the year

ATHENA GLOBAL TECHNOLOGIES LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(4), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 194A(3)(iii) of the Act, as per which, no TDS is required to be deducted on payment of bank interest and accordingly no disallowance could be made u/s 40(a)(ia) of the Act. Further, in case of disallowance of depreciation of Rs.1,27,840/-, the Ld. CIT(A) has not deleted the addition and in fact

INCOME TAX OFFICER, WARD-1(2), HYDERABAD vs. ATHENA GLOBAL TECHNOLOGIES LIMITED (FORMERLY M/S VJIL CONSULTING LIMITED), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 194A(3)(iii) of the Act, as per which, no TDS is required to be deducted on payment of bank interest and accordingly no disallowance could be made u/s 40(a)(ia) of the Act. Further, in case of disallowance of depreciation of Rs.1,27,840/-, the Ld. CIT(A) has not deleted the addition and in fact

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-8(1), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 194A(3)(iii) of the Act, as per which, no TDS is required to be deducted on payment of bank interest and accordingly no disallowance could be made u/s 40(a)(ia) of the Act. Further, in case of disallowance of depreciation of Rs.1,27,840/-, the Ld. CIT(A) has not deleted the addition and in fact

KRISHNA HARI GADDAM,HYDERABAD vs. ITO., WARD-12(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं/Ita No.668/Hyd/2023 (नििाारण वर्ा/Assessment Year: 2020-21) Krishna Hari Gaddam, Vs. Income Tax Officer, Hyderabad Ward-12(1), [Pan No. Adepg7798Q] Hyderabad अपीलार्थी/Appellant प्रत् यर्थी/Respondent नििााररती द्वारा/Assessee By: Shri H. Srinivasulu, Ar राजस् व द्वारा/Revenue By: Shri Shakeer Ahamed, Dr सुिवाई की तारीख/Date Of Hearing: 29/04/2024 घोर्णा की तारीख/Pronouncement On: 30/04/2024 आदेश / Order Per Madhusudan Sawdia, A.M: The Captioned Appeal Filed By The Assessee Is Directed Against The Order Dated 02/11/2023 Passed By The Addl/Jcit(A)-5, Chennai, (“Ld. Cit(A)”) Relating To The Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Assessee Was A Salaried Employee Of Karvy Stock Broking Limited. For The Year Under Consideration, The Assessee Fled His Return Of Income, Declaring A Total Income Of Rs. 86,10,680/- & Paid Total Income Tax Of Rs. 27,37,674/-, Consisting Of Tax Deducted At Source (“Tds”) Of Rs. 15,11,384/- & Self Assessment Tax Of Rs.12,26,290/-. The Cpc Bengluru (“Cpc”) In The Intimation U/S 143(1) Of The Income Tax Act, 1961 (“The Act”), Dt. 08/05/2021 Did Not Give Credit Of Rs. 13,50,000/- Out Of Total Tds Of Rs. 14,75,000/- Deducted By M/S. Karvy Stock Broking Limited U/S. 192 Of The Act, Contending That Form 26As Does Contains The Details Of Tds Of Rs. 13,50,000/- & Finally Raised A Demand Of Rs.14,17,500/-.

194A, 1948 and 19488, respectively. 8.2 Likewise, payments made to contractors and insurance commission, payments made in respect of life insurance policy, and payments made to the non-resident. sportsmen or sports associations are liable for deduction of tax at source under sections 194C, 1940, 1940A, and 194E, respectively. 8.3 As far as payments made to non-residents (not being