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 under Section 40(a)(ia) of the Act separately. Therefore, once again making additions on the basis of seized documents is incorrect. Since the assessee is able to reconcile the difference by filing relevant evidence, in our considered view, the additions made by the A.O. on the basis of provisional financial statements cannot be upheld. Therefore, we direct

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

27,12,098/- for its branch office in India. The case of the assessee was selected for scrutiny and accordingly, notice under section 143(2) of the Income Tax Act, 1961 (“the Act”) was issued on 27.06.2022. As the assessee was an eligible assessee within the Page 2 of 20 ITA No 670 of 2023 Nippon Koei Co Ltd meaning

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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.

TDS provisions of Section 194A are not attracted to Judgment Debtors. We draw your kind attention to the following case laws: 1. Madhusudan Shrikrishna Vs Emkay Exports 188 Taxman 195 (Born HC)Paper Book pages 54 to 55.” 27

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 have not been accepted in full but taking into consideration the reasonableness of explanation, the penalty chargeable under section 272A(2)(k) of the Act has been restricted i.e. suitably reduced in the case of appellant as held by the Hon'ble High Court. :- 15 -: ITA Nos. 1528 to 1530Hyd/2016 27

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 have not been accepted in full but taking into consideration the reasonableness of explanation, the penalty chargeable under section 272A(2)(k) of the Act has been restricted i.e. suitably reduced in the case of appellant as held by the Hon'ble High Court. :- 15 -: ITA Nos. 1528 to 1530Hyd/2016 27

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 have not been accepted in full but taking into consideration the reasonableness of explanation, the penalty chargeable under section 272A(2)(k) of the Act has been restricted i.e. suitably reduced in the case of appellant as held by the Hon'ble High Court. :- 15 -: ITA Nos. 1528 to 1530Hyd/2016 27

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

Bench: Us:

section 139(1) of the Act, i.e., up to the “due date” of 31/10/2013, disallowed its claim for carry forward loss of Rs. 27,58,236/-. 5. The AO observed that the information available on record revealed that the assessee company had contractual receipts of Rs. 3,20,42,152/- on which tax was deducted at source (TDS

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

27. Ground No.5 by the assessee relates to the disallowance of sub- contract payment of Rs.47,06,061/- on account of non-deduction of tax at source. Learned AR, at the time of hearing, submitted that the assessee deducted the TDS and, therefore, this issue may be restored to the file of the learned Assessing Officer for due verification

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

27. Ground No.5 by the assessee relates to the disallowance of sub- contract payment of Rs.47,06,061/- on account of non-deduction of tax at source. Learned AR, at the time of hearing, submitted that the assessee deducted the TDS and, therefore, this issue may be restored to the file of the learned Assessing Officer for due verification

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DCIT, CIRCLE -2(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

27. Ground No.5 by the assessee relates to the disallowance of sub- contract payment of Rs.47,06,061/- on account of non-deduction of tax at source. Learned AR, at the time of hearing, submitted that the assessee deducted the TDS and, therefore, this issue may be restored to the file of the learned Assessing Officer for due verification