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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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

32(1)(iia) of the Act, no corresponding amendment is made\nin section 32AC of the Act and therefore, the intention of the\nLegislature is clear that the benefit of section 32AC(1) is not\navailable to a company engaged in the business of generation of\npower. To maintain the rule of consistency, we follow the earlier\ndecision

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

In the result, assessee's appeals for the A

32(1)(iia) of the Act, no corresponding amendment is made\nin section 32AC of the Act and therefore, the intention of the\nLegislature is clear that the benefit of section 32AC(1) is not\navailable to a company engaged in the business of generation of\npower. To maintain the rule of consistency, we follow the earlier\ndecision

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

32(ii) of the Act in respect of the above programs/rights. As such, the Ld DR's argument on the applicability of the AS-26 to the TV Programs and Film rights is not supported by any precedents and therefore, the arguments raised by the Revenue are not allowed. Thus, considering the covered nature of the issue as well

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)

Section 40(a)(ia) of the Income-tax Act, 1961 for non-deduction of TDS on subcontract works. The A.O. disallowed Rs. 2,91,31,153/- @ 30% of the expenditure incurred towards subcontract payment to Bathini Infra of Rs. 5,47,454/-, Rs.4,13,765/- incurred towards subcontract payment to Shankarapally, Rs. 2,76,00,000/- incurred towards subcontractor works

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)

Section 40(a)(ia) of the Income-tax Act, 1961 for non-deduction of TDS on subcontract works. The A.O. disallowed Rs. 2,91,31,153/- @ 30% of the expenditure incurred towards subcontract payment to Bathini Infra of Rs. 5,47,454/-, Rs.4,13,765/- incurred towards subcontract payment to Shankarapally, Rs. 2,76,00,000/- incurred towards subcontractor works

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)

Section 40(a)(ia) of the Income-tax Act, 1961 for non-deduction of TDS on subcontract works. The A.O. disallowed Rs. 2,91,31,153/- @ 30% of the expenditure incurred towards subcontract payment to Bathini Infra of Rs. 5,47,454/-, Rs.4,13,765/- incurred towards subcontract payment to Shankarapally, Rs. 2,76,00,000/- incurred towards subcontractor works

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

32 of the Act in respect of goodwill arising on amalgamation and recognized in the books as per the Hon'ble NCLT order sanctioning the amalgamation. 4. That on the facts and in the circumstances of the case and in law, the Ld. AO erred in disallowing INR 42.97.430 under section 14A of the Act and the Ilon

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

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana

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 204( iii) of the Income-tax Act. However, we had requested the Department to confirm the factual position from the Ministry of Rural Development. The Department of Rural Development have stated that the person responsible for payment of compensation under Land Acquisition Act is the Collector. In Baldeep Singh v. UOI [1993] 199 ITR 628 the Punjab and Haryana