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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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

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

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

TDS under Section 37(1) of the Act. Thus, we are inclined to uphold the findings of the learned CIT(A) and reject the ground taken by the assessee. 20. The next issue that came up for our consideration from ground no. 5 of the assessee's appeal is disallowance of interest expenditure under Section 36(1

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

1) of the Act. The same cannot be countenanced as against the spirt of the Act, as the Act contemplates that making of the payment within the time, and the consequences are provided under Sections 220 and 221 of the Act, which not only require the payment of interest but also, in case of failure to make

RAIN CEMENTS LIMITED, HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2008-09 M/S. Rain Cements Ltd Vs. Dy. Commissioner Of (Formerly Known As Rain Income Tax, Circle 3 (1) Cii Carbon (India) Ltd Hyderabad Hyderabad Pan:Aabcr8858F (Appellant) (Respondent) Assessee By: Advocate Prathishta Singh & Advocate Deepak Chopra Revenue By: Dr.Rajendra Kumar, Cit-Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 24.03.2017 Passed U/S 143(3) R.W.S. 144C(5) R.W.S. 260 Of The I.T. Act For The A.Y 2008-09. 2. This Appeal Was Earlier Decided By The Tribunal Vide Order Dated 18.10.2019. Subsequently Vide Ma No.15/Hyd/2020, Dated 23.3.2021, The Tribunal Recalled The Entire Order For Fresh Adjudication. Therefore, This Is A Recalled Matter.

221/- and determined the taxable income at Rs. Nil. He however, accepted the book profit declared by the assessee at Rs.70,09,87,659/-. 4. The assessee filed an appeal before the learned CIT(A) which was pending for disposal. Page 2 of 35 ITA No 864 of 2017 Rain Cements Ltd Hyderabad 5. In the meantime, the Assessing Officer

DHARTI DREDGING & INFRASTRUCTURE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1) TDS, HYDERABAD

Appeal is dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

TDS into the Govt. account within the prescribed time as required under section 200(1), then such deductor is deemed to be an assessee in default. Further, as per the provisions of section 221

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

221/- from Wells India in respect of which the tax at source was deducted to the tune of Rs. 12,44,487/- under section 192(1) of the Act. On 18/10/2018 the employment of the assessee was terminated by Wells India and the terminal benefits were paid to him. Assessee claimed that he was part

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

ASST. COMMISSIONER OF INCOME TAX CIRCLE-1,, KHAMMAM vs. M/S SINGARENI COLLERIES COMPANY LTD.,, KHAMMAM DIST

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

ASST. COMMISSIONER OF INCOME TAX CIRCLE-1,, KHAMMAM vs. M/S SINGARENI COLLERIES COMPANY LTD.,, KHAMMAM DIST

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

THE SINGARENI COLLERIES COMPANY LTD., KOTHJAGUDEM,HYDERABAD vs. ADDL.CITT, KHAMMAM RANGE, KHAMMAM, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

ASST. COMMISSIONER OF INCOME TAX CIRCLE-1,, KHAMMAM vs. M/S SINGARENI COLLERIES COMPANY LTD.,, KHAMMAM DIST

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

SINGARENI COLLERIES COMPANY LIMITED,HYDERABAD vs. ACIT, CIRCLE-1,, KHAMMAM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

DCIT, CIRCLE-1, KHAMMAM, KHAMMAM vs. THE SINGARENI COLLERIES COMPANY LT.D, KOTHAGUDEM, KOTHAGUDEM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 35E. Therefore, this ground may be treated as not pressed. We draw your attention to the following decisions: 1. CIT Vs Hindustan Zinc Ltd 221 CTR 631 Paper book pages 16-20 Head note 2. Hindustan Aluminium Corp Ltd Vs CIT 159 ITR 673 (Cal HC) Paper Book pages 21 to 23. 3. Northern Coalfields Ltd Vs ACIT

KALBURGI CEMENT PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

221/-)” 2. Brief facts of the case : The brief facts of the case are that assessee company engaged in the business of manufacture of cement, filed its return of income on 28.11.2018 declaring total income of Rs. Nil. The case was selected for scrutiny through the CASS and notice u/s 143(2) of the Act was issued