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

Bench: Us:

7 Sanghi Textiles Privarte Limited vs. ITO 9. Thereafter, the AO vide his order passed under section 147 r.w.s 144B of the Act, dated 30/03/2022, after making the aforesaid additions/disallowances, determined the income of the assessee company at Rs. 1,40,65,678/-. 10. Aggrieved, the assessee company carried the matter in appeal before the CIT(A) but without success

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

section 200(3) of the I.T. Act any person deducting any sum in accordance with the TDS provisions is required to prepare and deliver the quarterly TDS statements in form No. 24Q and 26Q in respect of TDS on salaries and on payments other than salaries respectively Within the prescribed time. As per :- 5 -: ITA Nos. 1528 to 1530Hyd/2016 Rule

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

section 200(3) of the I.T. Act any person deducting any sum in accordance with the TDS provisions is required to prepare and deliver the quarterly TDS statements in form No. 24Q and 26Q in respect of TDS on salaries and on payments other than salaries respectively Within the prescribed time. As per :- 5 -: ITA Nos. 1528 to 1530Hyd/2016 Rule

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

section 200(3) of the I.T. Act any person deducting any sum in accordance with the TDS provisions is required to prepare and deliver the quarterly TDS statements in form No. 24Q and 26Q in respect of TDS on salaries and on payments other than salaries respectively Within the prescribed time. As per :- 5 -: ITA Nos. 1528 to 1530Hyd/2016 Rule

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

7 of 13 ITA-TP Nos. 145 & 482/Hyd/2022 requirement of sub-section (5) of section 80G of the Act, then 50% of the donation is allowable expenditure [refer section 80G (1) (ii)]even if the assessee has included the expenditure as CSR Expenditure because there is no prohibition or restriction placed by the Parliament on such a donation even

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

7 of 13 ITA-TP Nos. 145 & 482/Hyd/2022 requirement of sub-section (5) of section 80G of the Act, then 50% of the donation is allowable expenditure [refer section 80G (1) (ii)]even if the assessee has included the expenditure as CSR Expenditure because there is no prohibition or restriction placed by the Parliament on such a donation even

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

TDS),\nCPC, Ghaziabad, considering the TDS/TCS statements passed orders under\nsection(s) 200A/206CB r.w.s 154 r.w.s 200A for the respective quarters,\nwherein demands under section 201(1A), 234E and 220(2) were raised, as\nunder:\nForm No.\nQuarter\nDate of Date of\nfiling of\nfiling of\nquarterly rectification\nreturn\nOrder u/s.\nby CPC\nDate of 234E 201(1A) 220(2

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

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 deducted on various expenses, the A.O. made addition of Rs. 2,23,33,770/- @ 30% of subcontract works of Rs. 7,44,45,893/- and added the same 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 deducted on various expenses, the A.O. made addition of Rs. 2,23,33,770/- @ 30% of subcontract works of Rs. 7,44,45,893/- and added the same 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 deducted on various expenses, the A.O. made addition of Rs. 2,23,33,770/- @ 30% of subcontract works of Rs. 7,44,45,893/- and added the same under Section

KARTHIKEYA HOTELS,HYDERABAD vs. INCOME TAX OFFICER TDS, WARD-1(4), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: the Tribunal. Shri D. Veera Reddy, being the partner of the assessee and who looks after the affairs of the assessee, has filed an affidavit explaining the reasons that, the appeal relates to proceedings under Section 206C of the Income Tax Act, 1961 and that the order of Ld. CIT(A) dated 27.02.2025 was received by email on 27.02.2025. The partner of the assessee was not well and was having medical issues which required frequent visits to the hospitals and upon performing various procedures

Section 206C(7) of the Act, and the A.O. shall reconsider the issue after providing reasonable opportunity of being heard to the assessee. 9 Karthikeya Hotels 12. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the Open Court on 12th December, 2025. श्री विजय पाल राि (मंजूनाथ जी) (VIJAY PAL RAO) (MANJUNATHA

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:

2. ..... The terms and conditions of the service of the workmen working in coal mines are inter alia governed by a "settlement" known as National Coal Wage Agreement (NCWA) V. Indisputably, the said settlement, in terms of sub- section (3) of Section 18 of the Industrial Disputes Act, 1947 is binding on the parties.....". 1 (2007) 8 Supreme Court Cases

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:

2. ..... The terms and conditions of the service of the workmen working in coal mines are inter alia governed by a "settlement" known as National Coal Wage Agreement (NCWA) V. Indisputably, the said settlement, in terms of sub- section (3) of Section 18 of the Industrial Disputes Act, 1947 is binding on the parties.....". 1 (2007) 8 Supreme Court Cases

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:

2. ..... The terms and conditions of the service of the workmen working in coal mines are inter alia governed by a "settlement" known as National Coal Wage Agreement (NCWA) V. Indisputably, the said settlement, in terms of sub- section (3) of Section 18 of the Industrial Disputes Act, 1947 is binding on the parties.....". 1 (2007) 8 Supreme Court Cases

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:

2. ..... The terms and conditions of the service of the workmen working in coal mines are inter alia governed by a "settlement" known as National Coal Wage Agreement (NCWA) V. Indisputably, the said settlement, in terms of sub- section (3) of Section 18 of the Industrial Disputes Act, 1947 is binding on the parties.....". 1 (2007) 8 Supreme Court Cases

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)

7. Erred in upholding the action of the Ld. AO invoking Section 92CA(1) by not acknowledging the fact that reason for reopening the assessment was other than for Transfer Pricing matter. Thus, the reference under section 92CA(1) by the Ld. AO is bad in law and is liable to be quashed. 8. Erred in confirming the action

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

TDS deduction on the interest payment on\ncompensation/enhanced compensation which is as under:\n“18/05/2021 Circular No. 526, dated 05-12-1988 1055.\nWhether interest payments under Land Acquisition Act are\ncovered by section on 194A According to section 194A of the\nIncome-tax Act, 1961, any person, not being an individual\nor HUF, who is responsible for paying

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

7. Assessee is therefore, before us in this appeal contending that the authorities below should have allowed the exemption claimed by the assessee under Article 16 (1) of the DTAA read with section 90 of the Act and should have held that the employment was exercised in USA where the services are rendered and also because during that period