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

Bench: Us:

TDS credits. Hence, the addition of Rs. 92,069/-is sustained. 5.4. The appellant has raised several grounds 5.4. The against the addition of Unexplained Investment u/s 69B at Rs.19,54,348/- The AO made an addition of Rs. 19,54,348/- as unexplained time deposits since no source was explained during the assessment proceedings. The appellant contends that these

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

TDS credit in respect of Rail Tel Corporation of India also in accordance with law. 18. Interest under section 234B is consequential in nature whereas the issue relating to the interest under section 234C of the Act has been resolved by order dated 03/09/2022. 19. In view of the above, this appeal of assessee is allowed. Assessment Year

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

TDS credit in respect of Rail Tel Corporation of India also in accordance with law. 18. Interest under section 234B is consequential in nature whereas the issue relating to the interest under section 234C of the Act has been resolved by order dated 03/09/2022. 19. In view of the above, this appeal of assessee is allowed. Assessment Year

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

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

19. Insofar as the interest on TDS of Rs. 285/- is concerned, we find that, the A.O. has disallowed 30% of Rs. 285/- on the ground that, the assessee has not deducted TDS, however, fact remains that, the said amount is not a payment to subcontractors charges but only the interest paid on TDS, which is not an item

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee for A

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

19. Insofar as the interest on TDS of Rs. 285/- is concerned, we find that, the A.O. has disallowed 30% of Rs. 285/- on the ground that, the assessee has not deducted TDS, however, fact remains that, the said amount is not a payment to subcontractors charges but only the interest paid on TDS, which is not an item

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

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

19. Insofar as the interest on TDS of Rs. 285/- is concerned, we find that, the A.O. has disallowed 30% of Rs. 285/- on the ground that, the assessee has not deducted TDS, however, fact remains that, the said amount is not a payment to subcontractors charges but only the interest paid on TDS, which is not an item

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(4), HYDERABAD

Accordingly, the appeal filed by the assessee company, being devoid and bereft of any substance, is dismissed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1236 & 1237/Hyd/2025 ("नधा"रण वष"/Assessment Year:2021-22 & 2022-23) Vivimed Labs Limited, Vs. Dcit, Hyderabad. Central Circle-3(4), Pan: Aaacv6060A Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई क" तार"ख/Date Of 05/01/2026 Hearing: घोषणा क" तार"ख/Date Of 21/01/2026 Pronouncement: आदेश / Order

2) of the Act for the reason that there was a delay in delivering/filing the statements within the time prescribed under section 200(3) of the Act. The assessee company has assailed the charging of the interest/fee primarily for two-fold reasons, viz., (i) that as its accountant who was attending to the work relating to TDS provisions was during

PRASANTH NANDANURU,HYDERABAD vs. ITO, (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

TDS. Assessee contends that the employment is exercised where the services are rendered and at such place only the salary accrues, and, therefore, his salary had accrued in USA for the relevant period. His case is that 5(2)(b) of the Act his salary would be chargeable to tax in India only if it is accrued in India

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted the provisions of section 40(a)(ia) of the Act; and (ii) and though the assessee company had during the subject year carried out international transactions with its Associated Enterprises (AEs) of Rs.23,97,35,320/-, but the AO in the course

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:

2) of the Act to claim the deduction on account of bad debts written off. He has contended that on this issue, the Assessing Officer has taken a correct and plausible view while allowing the claim of deduction and the Commissioner has no power to invoke the provisions of sec.263 of the Act without verifying and analyzing relevant details

INCOME TAX OFFICER, WARD-16(4), HYDERABAD vs. QUARK ENTERPRISES PRIVATE LIMITED , HYDERABAD

In the result, the appeal filed by the revenue is allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Ito, Ward-16(4) Vs. M/S.Quark Enterprises 1St Floor, ‘B’ Block Private Limited I.T.Towers, A.C.Guards 10Th Floor, Ramky Masab Tank Grandoise Hyderabad Ramky Towers Complex Road No.62, Gachibowli Hyderabad-500 032

TDS Receivable Rs.28,666) Liabilities = RS.13,68,80,511 (40,07,29,479 - 25,60,00.01 0- 7,48, 958) Paid up capital = RS.25,60,00,010 5 ITA 1270/Hyd/2019 Paid up value of equity share =Rs.10 Represented: FMV of unquoted equity share = (40,07,00,813-13,68,80,511)x10= Rs.10.305 25,60,00,010 Premium per share

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub- section (1) of section 9 of the Act. The said latter provision defines royalty as follows : “ Section 9(1)(vi) - Explanation 2.—For the purposes of this clause, "royalty" means consideration (including

VODAFONE IDEA LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub- section (1) of section 9 of the Act. The said latter provision defines royalty as follows : “ Section 9(1)(vi) - Explanation 2.—For the purposes of this clause, "royalty" means consideration (including

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub- section (1) of section 9 of the Act. The said latter provision defines royalty as follows : “ Section 9(1)(vi) - Explanation 2.—For the purposes of this clause, "royalty" means consideration (including

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub- section (1) of section 9 of the Act. The said latter provision defines royalty as follows : “ Section 9(1)(vi) - Explanation 2.—For the purposes of this clause, "royalty" means consideration (including

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub- section (1) of section 9 of the Act. The said latter provision defines royalty as follows : “ Section 9(1)(vi) - Explanation 2.—For the purposes of this clause, "royalty" means consideration (including

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub- section (1) of section 9 of the Act. The said latter provision defines royalty as follows : “ Section 9(1)(vi) - Explanation 2.—For the purposes of this clause, "royalty" means consideration (including

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub- section (1) of section 9 of the Act. The said latter provision defines royalty as follows : “ Section 9(1)(vi) - Explanation 2.—For the purposes of this clause, "royalty" means consideration (including

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