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

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS returns under section 272A(2)(k) of the Act. Since section 273B of the Act covers the cases of levy of penalty under section 272A(2) of the Act, then in line with the provisions of said section in case a person establishes its case of reasonable cause for not complying with the provisions of said section, then

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS returns under section 272A(2)(k) of the Act. Since section 273B of the Act covers the cases of levy of penalty under section 272A(2) of the Act, then in line with the provisions of said section in case a person establishes its case of reasonable cause for not complying with the provisions of said section, then

TELANGANA STATE MEDICAL SERVICES INFRASTRUCTURE DEVELOPMENT CORPORATION, HYDERABAD,HYDERABAD vs. ADDL. CIT, TDS, RANGE-3, VIJAYAWADA, VIJAYAWADA

In the result, all three appeals under consideration are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS returns under section 272A(2)(k) of the Act. Since section 273B of the Act covers the cases of levy of penalty under section 272A(2) of the Act, then in line with the provisions of said section in case a person establishes its case of reasonable cause for not complying with the provisions of said section, then

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

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

2): Rs.12,032/-. The CIT(A) observed that the amount of\ninterest under section 201(1A) of Rs.48,529/- was comprised of, viz., (i) short\npayment of tax: Rs.17,004/-; (ii) short deduction/collection of tax: 13,660/-; and\n(iii) interest under section 201(1A): Rs.17,868/-. The CIT(A) observed that other\nthan the aforementioned discrepancy, the total disputed

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

TDS), CPC. 22. Apropos, the interest under section 220(2) of the Act, we are of the view that as the same

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)

TDS, which is not an item of disallowance under Section 40(a)(ia) of the Act. Therefore, the disallowance of Rs. 86/- under Section 40(a)(ia) of the Act, cannot be upheld. Accordingly, we direct the A.O. to delete the addition of Rs. 86/- made under Section

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)

TDS, which is not an item of disallowance under Section 40(a)(ia) of the Act. Therefore, the disallowance of Rs. 86/- under Section 40(a)(ia) of the Act, cannot be upheld. Accordingly, we direct the A.O. to delete the addition of Rs. 86/- made under Section

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)

TDS, which is not an item of disallowance under Section 40(a)(ia) of the Act. Therefore, the disallowance of Rs. 86/- under Section 40(a)(ia) of the Act, cannot be upheld. Accordingly, we direct the A.O. to delete the addition of Rs. 86/- made under Section

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)

22,193/-. 5. Thereafter, the AO observed based on the facts, viz., (i) that the assessee company had reimbursed some expenses of Rs.6,54,33,770/- to M/s. Countrywide Finance Corporation and M/s. CW(UK) Services without any deduction of tax at source (TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted

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:

22. The amendment to Section 32(1)(iia) of the Act was carried out w.e.f. 01.04.2013 whereby a distinct class i.e., "the business of generation, transmission, and distribution of power" was added to the already existing class of assessee engaged in "the business of manufacturing or production of any article or thing". However, despite this, when the legislature introduced Sections

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:

22. The amendment to Section 32(1)(iia) of the Act was carried out w.e.f. 01.04.2013 whereby a distinct class i.e., "the business of generation, transmission, and distribution of power" was added to the already existing class of assessee engaged in "the business of manufacturing or production of any article or thing". However, despite this, when the legislature introduced Sections

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:

22. The amendment to Section 32(1)(iia) of the Act was carried out w.e.f. 01.04.2013 whereby a distinct class i.e., "the business of generation, transmission, and distribution of power" was added to the already existing class of assessee engaged in "the business of manufacturing or production of any article or thing". However, despite this, when the legislature introduced Sections

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:

22. The amendment to Section 32(1)(iia) of the Act was carried out w.e.f. 01.04.2013 whereby a distinct class i.e., "the business of generation, transmission, and distribution of power" was added to the already existing class of assessee engaged in "the business of manufacturing or production of any article or thing". However, despite this, when the legislature introduced Sections

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

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

TDS to the tune of Rs. 30,211/- without assigning any reasons therefor. 10. The appellant craves leave to add, amend or alter any of the grounds during the course of hearing.” 2. Brief facts of the case are that the assessee-company is engaged in manufacturing of Clinker and Ordinary Portland Cement. The assessee, being the third largest cement

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:

22 ITA.No.625/Hyd./2025 failure on the part of assessee to establish that the debt is irrecoverable. 2. Direct Tax Laws (Amendment) Act, 1987 amended the provisions of sections 36(1)(vii) and 36(2) of the Income Tax Act 1961, (hereafter referred to as the Act) to rationalize the provisions regarding allowability of bad debt with effect from