DY. COMMISSIONER OF INCOME TAX-1, INTERNATIONAL TAXATION, HYDERABAD vs. EMAAR HILLS TOWNSHIP PRIVATE LIMITED , HYDERABAD

In the result, appeal of the Revenue is dismissed

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

section 201(1) and 201(1A) of the Act fastening the tax liability and interest thereon, by order dated 03/03/2014. 4. Aggrieved by such an action of the learned Assessing Officer, assessee preferred appeal before the learned CIT(A) and argued that the reimbursement does not require any TDS and further that the impugned order was also barred by limitation

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD, HYDERABAD vs. SUSHEE PRASAD JV, HYDERABAD

In the result, the appeal of the revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 The Assistant Commissioner Of Vs. Sushee Prasad Jv, Hyderabad, Income Tax, Circle – 6(1), Plot No.246/A/2, Road Hyderabad. No.12, Mla Colony, Banjara Hills, Telangana – 500034. Pan : Aapas3540R. (Appellant) (Respondent) Assessee By: Shri S. Ramarao, Advocate. Revenue By: Shri Sesha Srinivas, Cit-Dr Date Of Hearing: 06.03.2024 Date Of Pronouncement: 12.03.2024

TDS as mentioned in Section 40(a)(ia) of the Act r.w.s. first Proviso of Section 201(1) of the Act. The ld.CIT(A) has also held that in case the payee referred to in the first proviso to section 201(1) of the Act and had taken into account such return of income, then the assessee (Payee) shall

BHARAT FINANCIAL INCLUSION LIMITED (ERSTWHILE KNOWN AS SKS MICROFINCANCE LIMITED), HYDERABAD,HYDERABAD vs. DCIT (TDS), CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 Bharat Financial Inclusion Ltd. Dy. Commissioner Of Income- Vs. (Erstwhile Known As Sks Tax (Tds), Circle – 2(1), Microfinance Ltd.), Hyderabad Hyderabad. Pan – Aaics 2940J (Appellant) (Respondent)

2. Erred in holding the Appellant as assessee in default both in law as well as in facts for late deduction/deposit of Tax M/s Bharat Financial Inclusion Ltd. Deducted at Source ('TDS') to government treasury and levying interest u/s 201(1A) of the Act whereas the TDS was actually deposited within the prescribed due dates. 3. Without prejudice to Ground

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

sections. Accordingly, the assessee company filed the details of expenditure incurred and TDS deducted, and on the basis of the information filed by the assessee, the AO noticed Non-deduction of TDS on Auto Roaming Charges paid to other Telecom operators. Accordingly, orders u/s.201(1) & 201(IA) of the I.T. Act, 1961 were passed on by the AO, holding

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

sections. Accordingly, the assessee company filed the details of expenditure incurred and TDS deducted, and on the basis of the information filed by the assessee, the AO noticed Non-deduction of TDS on Auto Roaming Charges paid to other Telecom operators. Accordingly, orders u/s.201(1) & 201(IA) of the I.T. Act, 1961 were passed on by the AO, holding

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

sections. Accordingly, the assessee company filed the details of expenditure incurred and TDS deducted, and on the basis of the information filed by the assessee, the AO noticed Non-deduction of TDS on Auto Roaming Charges paid to other Telecom operators. Accordingly, orders u/s.201(1) & 201(IA) of the I.T. Act, 1961 were passed on by the AO, holding

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

sections. Accordingly, the assessee company filed the details of expenditure incurred and TDS deducted, and on the basis of the information filed by the assessee, the AO noticed Non-deduction of TDS on Auto Roaming Charges paid to other Telecom operators. Accordingly, orders u/s.201(1) & 201(IA) of the I.T. Act, 1961 were passed on by the AO, holding

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

sections. Accordingly, the assessee company filed the details of expenditure incurred and TDS deducted, and on the basis of the information filed by the assessee, the AO noticed Non-deduction of TDS on Auto Roaming Charges paid to other Telecom operators. Accordingly, orders u/s.201(1) & 201(IA) of the I.T. Act, 1961 were passed on by the AO, holding

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

sections. Accordingly, the assessee company filed the details of expenditure incurred and TDS deducted, and on the basis of the information filed by the assessee, the AO noticed Non-deduction of TDS on Auto Roaming Charges paid to other Telecom operators. Accordingly, orders u/s.201(1) & 201(IA) of the I.T. Act, 1961 were passed on by the AO, holding

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

sections. Accordingly, the assessee company filed the details of expenditure incurred and TDS deducted, and on the basis of the information filed by the assessee, the AO noticed Non-deduction of TDS on Auto Roaming Charges paid to other Telecom operators. Accordingly, orders u/s.201(1) & 201(IA) of the I.T. Act, 1961 were passed on by the AO, holding

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

In the result, the appeal of the assessee is partly allowed

201(1A) paid by the assessee does not assume the character of business expenditure and cannot be regarded as compensatory payment. The learned CIT(A), after considering the relevant facts, has rightly sustained the additions made by the A.O. towards disallowance of interest paid on TDS under Section 37(1) of the Act. Thus, we are inclined to uphold

ANALOGICS TECH INDIA LIMITED ,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS amount does not constitute the tax liability of the 7 assessee and instead, it pertains to the tax liability of the parties for whom the deduction was made and paid by the assessee. To further support this viewpoint, he drew a distinction between interest under section 201(IA) and interest under section 220(2

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

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

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

INCOME TAX OFFICER (INTERNATIONAL TAXATION), NELLORE vs. BADRI MANJULA , NELLORE

In the result, the appeal filed by the revenue is allowed and the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2009-10 Badri Hari Babu Vs. Ito(International 15/342, Subedarpet Taxation) Andra Pradesh Nellore Nellore-524 001

2. The CIT (A) grossly erred in directing the Assessing Officer to recompute the tax/demand u/s.201(1) of the Act and interest u/s 201(1A) of the Act, after verification of taxes raid by the payee/non- resident seller. 3. The CIT(A) erred in placing reliance on the amended provisions of Section 201

BADRI HARI BABU,NELLORE vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), HYDERABAD

In the result, the appeal filed by the revenue is allowed and the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2009-10 Badri Hari Babu Vs. Ito(International 15/342, Subedarpet Taxation) Andra Pradesh Nellore Nellore-524 001

2. The CIT (A) grossly erred in directing the Assessing Officer to recompute the tax/demand u/s.201(1) of the Act and interest u/s 201(1A) of the Act, after verification of taxes raid by the payee/non- resident seller. 3. The CIT(A) erred in placing reliance on the amended provisions of Section 201