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(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered and decided by the Hon'ble jurisdictional High Court in assessee’s own case for the A.Ys

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(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered and decided by the Hon'ble jurisdictional High Court in assessee’s own case for the A.Ys

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(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered and decided by the Hon'ble jurisdictional High Court in assessee’s own case for the A.Ys

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(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered and decided by the Hon'ble jurisdictional High Court in assessee’s own case for the A.Ys

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

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 not the only share holders, as contended by the AO above

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

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 not the only share holders, as contended by the AO above

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

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

iv), and its liability to deposit amounts received by it or deducted by it (Section 36(1)(va)) is, thus crucial. The former forms part of the employers’ income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied

SRI LAKSHMI ROAD TRANSPORT COMPANY,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1209/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) M/S Sri Lakshmi Road Vs. Dy. Cit Transport Company Circle 6(1) Hyderabad Hyderabad Pan:Aatfs6596A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri C. Maheshwar Reddy, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 24/11/2025 घोषणा की तारीख/Pronouncement: 26/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

36(1)(va) of the Act on account of employees’ contribution towards PF and ESI. He submitted that the intimation under section 143(1) of the Act was passed by the Page 3 of 10 ITA No 1209 of 2025 Sri Lakshmi Road Transport Co CPC on 16.10.2019, which was a period when the issue regarding allowability of employees’ contribution

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

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

TDS short credit. 4. In so far as the issue relating to the disallowance of deduction claimed under section 80G of the Act qua expenditure incurred in Corporate Social Responsibility ("CSR") is concerned, plea of the assessee is that the assessee donated/ contributed Rs. 3,79,83,500/- towards CSR during the financial year 2016-17 which was debited

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

TDS short credit. 4. In so far as the issue relating to the disallowance of deduction claimed under section 80G of the Act qua expenditure incurred in Corporate Social Responsibility ("CSR") is concerned, plea of the assessee is that the assessee donated/ contributed Rs. 3,79,83,500/- towards CSR during the financial year 2016-17 which was debited

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD vs. AMRUT PRASAD PATNAM , HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

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

1 that the amount was not taxable. g. Further. the appellant submits without prejudice to its claim that the amount represented TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections to state

SRINIVAS UPPU,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

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

1 that the amount was not taxable. g. Further. the appellant submits without prejudice to its claim that the amount represented TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections to state

P AMRUTH PRASAD,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the four appeals filed by the assessee as well as the only appeal filed by the Revenue are allowed for statistical purposes

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

1 that the amount was not taxable. g. Further. the appellant submits without prejudice to its claim that the amount represented TDS of Mis. Amsri Builders and not income of the appellant. If the income receipt falls U/s. 28(i) or U/s. 28(iv) of the Act, the appellant is entitled to choose either of the two sections to state