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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.283, 284 & 286/Hyd/2024 (निर्धारण वर्ष/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 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. Cit, Circle 13(1) Hyderabad Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / 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:

40A(9) of the IT Act are very clear in providing that any payment or contribution made by an employer on behalf of the employees to any fund, trust, society, association or person etc. would not be an allowable expenses except the payment made for expenses provided for under section 36(1)(iv) and (v). Admittedly the payments

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

DCIT,CENTRAL CIRCLE - 7, HYDERABAD vs. M/S MIDWEST GRANITE PRIVATE LIMITED., HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

DCIT,CENTRAL CIRCLE - 7, HYDERABAD vs. M/S MIDWEST GRANITE PRIVATE LIMITED., HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

M/S MIDWEST GRANITES PRIVATE LIMITED,HYDERABAD vs. ACIT,CENTRAL CIRCLE - 7, HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

DCIT,CENTRAL CIRCLE - 7, HYDERABAD vs. M/S MIDWEST GRANITE PRIVATE LIMITED., HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

DCIT,CENTRAL CIRCLE - 7, HYDERABAD vs. M/S MIDWEST GRANITE PRIVATE LIMITED., HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

DCIT,CENTRAL CIRCLE - 7, HYDERABAD vs. M/S MIDWEST GRANITE PRIVATE LIMITED., HYDERABAD

In the result, all the assessee’s appeals are partly allowed for statistical purposes and the Revenue’s appeals are dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

40A(2)(b) of the Act without examining the nature and scope of the work carried out by the proprietorship firm. It was therefore pleaded that the addition sustained by the Ld. CIT (A) may be deleted. Ld. DR on the other hand vehemently supported the order of the Ld. CIT (A). 23. We have heard the rival submissions

ACIT., CIRCLE-16(2), HYDERABAD, HYDERABAD vs. M/S M S AGARWAL FOUNDRIES PRIVATE LIMITED, HYDERABAD

In the result both the appeals of the revenue are dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS has been deducted and paid on the amounts paid to APK Road Carriers by the assessee, and the same is also reflected in the Form 26AS of :- 10 -: ITA Nos. 279/Hyd/2013 & 1719/H/2014 M/s Agarwal Foundries Pvt. Ltd., Hyd. APK Road Carriers produced before me. Further, receipt of the transportation amount is confirmed by APK Road Carriers and the same

ITO, WARD-6(2),, HYDERABAD vs. MS AGARWAL FOUNDRIES PRIVATE LIMITED,,, SECUNDERABAD

In the result both the appeals of the revenue are dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

TDS has been deducted and paid on the amounts paid to APK Road Carriers by the assessee, and the same is also reflected in the Form 26AS of :- 10 -: ITA Nos. 279/Hyd/2013 & 1719/H/2014 M/s Agarwal Foundries Pvt. Ltd., Hyd. APK Road Carriers produced before me. Further, receipt of the transportation amount is confirmed by APK Road Carriers and the same

SHASHIKALA RAM KUMAR ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, appeal of the assessee is allowed in part

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

B”, HYDERABAD BEFORE SHRI RAMA KANTA PANDA, VICE PRESIDENT & SHRI K.NARASIMHA CHARY, JUDICIAL MEMBER आ.अपी.सं / ITA No. 2382/Hyd/2018 (निर्धारण वर्ष / Assessment Year: 2014-15) Smt. Shashikala Ram Kumar, Vs. Asst. Commissioner of Hyderabad Income Tax, [PAN No. AGPPR1448G] Circle-4(1), Hyderabad अपीलार्थीर्थी / Appellant प्रत्‍यर्थी / Respondent निर्धारितीती द्वारा / Assessee by: Shri A. Srinivas, AR राजस्‍वजस्‍व द्वारा / Revenue

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:

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

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:

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

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:

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