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 and further disallowance of EPF & ESI under Section 36(1)(va) for Rs. 3,66,095/-, addition towards disallowance of interest expenditure under Section 36(1)(iii

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is partly allowed

iii) to disallow expenditure amounting to Rs.2,69,26,757 relatable to issue of foreign currency convertible bonds. Aggrieved by the order of the Ld. CIT under section 263 of the I.T. Act, the assessee preferred an appeal before the ITAT. The ITAT vide orders dated 04.01.2013 in ITA.No.749/Hyd/2012 upheld the initiation of proceedings under section

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

TDS has been deducted on the said interest. Accordingly, the AO disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

TDS has been deducted on the said interest. Accordingly, the AO disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

TDS has been deducted on the said interest. Accordingly, the AO disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

TDS has been deducted on the said interest. Accordingly, the AO disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

TDS has been deducted on the said interest. Accordingly, the AO disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

36,56,501 2023-24 1,61,80,065 1,12,87,744 Total 171,80,16,158 125,50,48,707 3. In view of the above, there is information which suggests that income chargeable to tax has escaped assessment in the case of the assessee company and this office is in possession of books of accounts or other

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

36,56,501 2023-24 1,61,80,065 1,12,87,744 Total 171,80,16,158 125,50,48,707 3. In view of the above, there is information which suggests that income chargeable to tax has escaped assessment in the case of the assessee company and this office is in possession of books of accounts or other

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED, HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

iii) bonus payments was a device for tax evasion; (iv) the directors had distributed dividend in the form of bonus and therefore payment was covered by the exceptions provided in section 36(1)(ii). 8.3 In the appellate proceedings, the appellant has brought out that the two directors Shri G. Ranjith Reddy and Shri. A. Thirupathi Reddy were

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED , HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

iii) bonus payments was a device for tax evasion; (iv) the directors had distributed dividend in the form of bonus and therefore payment was covered by the exceptions provided in section 36(1)(ii). 8.3 In the appellate proceedings, the appellant has brought out that the two directors Shri G. Ranjith Reddy and Shri. A. Thirupathi Reddy were

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:

36 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 17. Thus, it was held that despite the amendment in section 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

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:

36 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 17. Thus, it was held that despite the amendment in section 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

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:

36 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 17. Thus, it was held that despite the amendment in section 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

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:

36 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 17. Thus, it was held that despite the amendment in section 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

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS details show that the assessee is the subcontractor ii. Unsecured Loans include mobilization advances and these are all work contract receipts. iii. Clause 10(a) of the Tax Audit report describes the nature of the business of the assessee as a 'Civil Contractor' iv. In the P&L account, 'Revenue from Operations' reflects 'Work Contract Receipts'. 18. He submitted

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

TDS details show that the assessee is the subcontractor ii. Unsecured Loans include mobilization advances and these are all work contract receipts. iii. Clause 10(a) of the Tax Audit report describes the nature of the business of the assessee as a 'Civil Contractor' iv. In the P&L account, 'Revenue from Operations' reflects 'Work Contract Receipts'. 18. He submitted

PROGRESSIVE CONSTRUCTIONS LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.625/Hyd/2025 Assessment Year 2021-2022 Progressive Constructions The Dcit, Limited, Hyderabad. Circle-5(1) Vs. Pin – 500 001. Telangana. Hyderabad - 500 004. Pan Aabcp2274M Telangana. (Appellant) (Respondent) Ca Pawan Kumar Chakrapani िनधा"रती "ारा/Assessee By : & Sri Santi Pavan Kumar, Advocate राज" व "ारा/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 02.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

36 ITA.No.625/Hyd./2025 8. With respect to contract receipts or fees u/s 194C shown in ITR, kindly provide the following details: i) Name of the party ii) Section under which tax was deducted iii) Please provide detail of Income credited in 26AS vis-à-vis ITR; and also explain the reasons for difference, if any iv) Please provide detail

CRUSTUM PRODUCTS PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, appeal of the assessee is partly allowed for statistical purposes as indicated herein above

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year:2013-14 Crustum Products Private Vs. Dy. Cit, Limited, Circle-1(2), Hyderabad. Hyderabad. Pan: Aaccc 5920 C (Appellant) (Respondent) Assessee By: Shri P. Murali Mohana Rao Revenue By: Shri Rohit Mujumdar, Dr Date Of Hearing: 16/12/2020 Date Of Pronouncement: 06/01/2021 Order Per A. Mohan Alankamony, Am.:

36(1)(iii) of the Act. (ii) The Ld. CIT (A) has erred in upholding the order of the Ld. AO who had made an addition of Rs. 2,73,183/- being the disallowance of interest paid on late payment of TDS Rs. 1,19,167/- and the penalty levied thereon amounting to Rs. 1,54,016/- invoking the provisions