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 40(a)(ia) wherein it was stated that any amount of interest exceeding prescribed limit paid or credited without deducting tax at source or deducting tax at source but failed to remit the TDS to the Govt. account, such interest has to be disallowed. …………………………………………………….. Page 38 of 53 ITA Nos 283 284 286 and 300 301

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 40(a)(ia) wherein it was stated that any amount of interest exceeding prescribed limit paid or credited without deducting tax at source or deducting tax at source but failed to remit the TDS to the Govt. account, such interest has to be disallowed. …………………………………………………….. Page 38 of 53 ITA Nos 283 284 286 and 300 301

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 40(a)(ia) wherein it was stated that any amount of interest exceeding prescribed limit paid or credited without deducting tax at source or deducting tax at source but failed to remit the TDS to the Govt. account, such interest has to be disallowed. …………………………………………………….. Page 38 of 53 ITA Nos 283 284 286 and 300 301

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

301 & 308/Hyd/2024\n(निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21)\nVs.\nDy. CIT, Circle 13(1)\nHyderabad\n(Appellant)\nSingareni Collieries\nCompany Limited\nKothagudem\nPAN:AAACT8873F\n(Respondent)\nनिर्धारिती द्वारा / Assessee by: Shri M.V.Anil Kumar, Advocate\nराजस्व द्वारा / Revenue by:: Shri B Balakrishna, CIT (DR)\nसुनवाई की तारीख / Date of hearing: 10/06/2025\nघोषणा की तारीख / Pronouncement: 12/06/2025

SAMBASIVA RAO JARUGULA,HYDERABAD vs. CIT, DELHI NFAC

In the result, appeal of the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahua.Y.: 2013-14 Sambasiva Rao Jarugula, Vs. Income-Tax Officer Hyderabad. (Tds), Ward – 2(3), Hyderabad. Pan – Adrpj 9806D (Appellants) (Respondent) Assessee By: Shri P.R. Bharath Kumar & Shri Kiran Kash Revenue By: Shri Rohit Mujumdar, Cit-Dr Date Of Hearing: 24/11/2021 Date Of Pronouncement: 26/11/2021

section 200A w.e.f. 01.06.2015, giving power to make adjustment on account of fees u/s 234E while processing returns u/s 200A to be retrospective in nature, stating that this power given to the AO is a machinery provision while the substantive provision of the power to levy fees u/s 234E was always there on the Statute from :- 3 -: Sambasiva Rao Jarugula

ACIT., CIRCLE-1(1), TIRUPATI vs. PONNAMBALAM KRISHNAN, CHITTOOR

In the result, the appeal of the revenue and cross objections of the assessee are partly allowed for statistical purposes in above terms

Bench: Shri Manjunatha G, Accountnat Member & Shri Prakash Chand Yadavआ.अपी.सं /Ita No.655/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2017-18) Asst. Commissioner Of Income Shri Ponnambalam Krishnan, Tax, Circle 1(1), Tirupati. Vs. Ekjambarakuppam, Chittoor, A.P. Pan : Bedpk5641B (Appellant) (Respondent) C.O. No.11/Hyd/2024 (Assessment Year:2017-18) (By Assessee) निर्धाररती द्वधरध/Assessee By: Shri E. Phalguna Kumar, C.A. रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala,Sr-Dr सुिवधई की तधरीख/Date Of 10/09/2024 Hearing: घोर्णध की रीख/Pronouncement: 20/09/2024

301 ITR 404 (Raj) 18. In the above cases, it has been unanimously held that provisions of section 68 can only be applied for the current year credits. Therefore, we affirm the view of the Ld. CIT(A) and delete the addition of Rs.91,32,966/-. 19. So far as the remaining credits of Rs.7,43,028/-, we remit

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

In the result, assessee's appeals for the A

301 & 308/Hyd/2024\n(निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21)\nVs.\nDy. CIT, Circle 13(1)\nHyderabad\nSingareni Collieries\nCompany Limited\nKothagudem\nPAN:AAACT8873F\n(Appellant)\n(Respondent)\nनिर्धारिती द्वारा / Assessee by: Shri M.V.Anil Kumar, Advocate\nराजस्व द्वारा / Revenue by:: Shri B Balakrishna, CIT (DR)\nसुनवाई की तारीख / Date of hearing: 10/06/2025\nघोषणा की तारीख / Pronouncement: 12/06/2025

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

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

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

301 (Mad) - Condonation of delay of 754 days rejected. Each day delay needs to be explained. 3. Varna Apparels (I) Pvt Ltd Vs ACIT 102 Taxman 398, 2019 (Born) - Condonation petition for 507 days delay rejected.” 6.7 We have considered the written submissions and the letter dt.29.09.2023 filed by the Revenue. On perusal of the letter dt.17.02.2010 which was referred

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

301, Varija Enclave,\nGudimalkapur, Mehdipatnam,\nHyderabad-500063.\n2.\nSri Mohd Feroz Khan S/o Mohd.\nIbrahim Khan, 17-1-375/31/A,\nHusnabad, Santosh Nagar,\nHyderabad-500059.\n\nOn being called by Sri Bandla Dinesh Aditya, DDIT (Inv.) on 04.01.2023 at 06.50\na.m.fp.m. we, the above named panchas, presented ourselves at the above place of search.\nThe authorized officer, Bandla Dinesh

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

section 149(1) of the\nAct, as existed at the relevant point of time and submitted that\nthe asset which include immovable property being land or\nbuilding or both, shares and securities, loans & advances,\ndeposits in the bank account.\nIn support of his contention he has\nrelied upon the judgment of the Hon'ble Delhi High Court in case

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. ACIT.,CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the appeals of the assessee for the\nA

section 148 of the\nIncome Tax Act, 1961\n(YOGESH KUMAR VERMA, IRS)\nPrincipal Commissioner of Income Tax (Central),\nHyderabad.\nDate: 6/10/23\n(SANJAY BAHADUR, IRS)\nDirector General of Income Tax (Inv).\nHyderabad.\n5. Thus, it is clear that an identical sanction was granted by the DGIT (Inv), Hyderabad for all the A.Ys.\n6. At the outset, we note that

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the appeals of the assessee for the\nA

section 148 of the\nIncome Tax Act, 1961\nImproper many\nis covered w/1149(1)(b).\nIsame of motive of/5148\nis ayyun.\nDate: 6/10/23\n(SANJAY BAHADUR, IRS)\nDirector General of Income Tax (Inv).\nHyderabad.\n5.\nThus, it is clear that an identical sanction was granted\nby the DGIT (Inv), Hyderabad for all the A.Ys.\n6.\nAt the outset, we note

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the appeals of the assessee for the\nA

Section 148 is bad in law.\n8. On the facts and circumstance of the case, Learned CIT(A) is not justified in sustaining the addition of Rs.46,06,858/ -.\n9. Any other ground or grounds that may be urged at the time of hearing of the appeal.”\n\n3.\nWe have considered the rival contentions as well as the relevant

EXEL RUBBER PRIVATE LIMITED,K.V.RANGAREDDY vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the appeals of the assessee for the\nA

Section 148 is bad in law.\n8. On the facts and circumstance of the case, Learned CIT(A)\nis not justified in sustaining the addition of Rs.46,06,858/ -.\n9. Any other ground or grounds that may be urged at the\ntime of hearing of the appeal.”\n\n3.\nWe have considered the rival contentions as well as the\nrelevant

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee for the A

section 149(1) of the\nAct, as existed at the relevant point of time and submitted that\nthe asset which include immovable property being land or\nbuilding or both, shares and securities, loans & advances,\ndeposits in the bank account. In support of his contention he has\nrelied upon the judgment of the Hon'ble Delhi High Court in case

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee for the A

301, Varija Enclave,\nGudimalkapur, Mehdipatnam,\nHyderabad-500063.\n\n2.\nSri Mohd Feroz Khan S/o Mohd.\nIbrahim Khan, 17-1-375/31/A,\nHusnabad, Santosh Nagar,\nHyderabad-500059.\n\nOn being called by Sri Bandla Dinesh Aditya, DDIT (Inv.) on 04.01.2023 at 06.50\na.m.fp.m. we, the above named panchas, presented ourselves at the above place of search.\nThe authorized officer, Bandla

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

section 149(1) of the\nAct, as existed at the relevant point of time and submitted that\nthe asset which include immovable property being land or\nbuilding or both, shares and securities, loans & advances,\ndeposits in the bank account. In support of his contention he has\nrelied upon the judgment of the Hon'ble Delhi High Court in case

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

section 149(1) of the\nAct, as existed at the relevant point of time and submitted that\nthe asset which include immovable property being land or\nbuilding or both, shares and securities, loans & advances,\ndeposits in the bank account. In support of his contention he has\nrelied upon the judgment of the Hon'ble Delhi High Court in case

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

section 149(1) of the\nAct, as existed at the relevant point of time and submitted that\nthe asset which include immovable property being land or\nbuilding or both, shares and securities, loans & advances,\ndeposits in the bank account. In support of his contention he has\nrelied upon the judgment of the Hon'ble Delhi High Court in case