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204 results for “TDS”+ Section 47clear

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Key Topics

Addition to Income70Section 153C69Section 143(3)52Section 13244Section 1039Disallowance39Search & Seizure39Deduction27TDS27Section 69

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

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

ITA 1187/HYD/2018[2014-15]Status: DisposedITAT Hyderabad28 Apr 2023AY 2014-15

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

For Appellant: Shri Sriram Seshadri, CAFor Respondent: Shri Rajendra Kumar,CIT-DR
Section 115JSection 142(1)Section 143(2)Section 14ASection 14A(3)Section 47

Showing 1–20 of 204 · Page 1 of 11

...
25
Section 139(1)25
Section 4024
Section 56
Section 56(2)(viia)
Section 56(2)(viiia)

47(vi) exempts the amalgamation from the purview of transfer, therefore section 56(2)(viia) cannot be invoked, as this is not a case of receipt of shares in isolation but the merger of all property irrespective of shares and also 56(2)(viia) is not applicable for such amalgamation, therefore the invocation of the said section in the case

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee for A

ITA 282/HYD/2025[2019-20]Status: DisposedITAT Hyderabad26 Nov 2025AY 2019-20

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

TDS under Section 194C of the Act. Therefore, we direct the A.O. to delete the additions made towards disallowance of subcontract payments to Bathini Infra and Shankarapally under Section 40(a)(ia) of the Act for Rs.5,47

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

ITA 280/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

TDS under Section 194C of the Act. Therefore, we direct the A.O. to delete the additions made towards disallowance of subcontract payments to Bathini Infra and Shankarapally under Section 40(a)(ia) of the Act for Rs.5,47

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

ITA 281/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

TDS under Section 194C of the Act. Therefore, we direct the A.O. to delete the additions made towards disallowance of subcontract payments to Bathini Infra and Shankarapally under Section 40(a)(ia) of the Act for Rs.5,47

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

ITA 301/HYD/2024[2016-17]Status: DisposedITAT Hyderabad12 Jun 2025AY 2016-17
For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 194Section 32ASection 37Section 40Section 40A(9)

TDS?\nAccordingly, we have heard Advocate Parchure for the\nDepartment Advocate Dewani for assessee. We find that the\nprovision for educational facilities is being made by assessee\nas a part of its obligation under various National Coal Wage\nAgreement (NCWA), which are legally enforceable in terms\nof Section 18 of the Industrial Dispute Act. The said\nprovision is also accepted

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

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

ITA 670/HYD/2023[2021-22]Status: DisposedITAT Hyderabad20 Nov 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri GSV Prasad, Anand Swaroop and S K Mohanty, CAsFor Respondent: : Smt. U. Mini Chandran, CIT(DR)
Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 201Section 37(1)Section 40Section 44D

47,02,323/- and assessed the total income of the assessee at Rs.9,74,14,421/-. 5. Aggrieved with the final order of the Ld. AO, the assessee preferred an appeal before this Tribunal. The Learned Authorized Representative (“Ld. AR”) submitted that the Ground No.1 of the assessee pertains to disallowance of Rs.2,10,265/- made

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

In the result, assessee’s appeals for the A

ITA 308/HYD/2024[AY-2020-2]Status: DisposedITAT Hyderabad12 Jun 2025

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:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

TDS? Accordingly, we have heard Advocate Parchure for the Department Advocate Dewani for assessee. We find that the provision for educational facilities is being made by assessee as a part of its obligation under various National Coal Wage Agreement (NCWA), which are legally enforceable in terms of Section 18 of the Industrial Dispute Act. The said provision is also accepted

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

In the result, assessee’s appeals for the A

ITA 300/HYD/2024[2015--16]Status: DisposedITAT Hyderabad12 Jun 2025

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:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

TDS? Accordingly, we have heard Advocate Parchure for the Department Advocate Dewani for assessee. We find that the provision for educational facilities is being made by assessee as a part of its obligation under various National Coal Wage Agreement (NCWA), which are legally enforceable in terms of Section 18 of the Industrial Dispute Act. The said provision is also accepted

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE- 1, KHAMMAM

In the result, assessee’s appeals for the A

ITA 283/HYD/2024[2015-16]Status: DisposedITAT Hyderabad12 Jun 2025AY 2015-16

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:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

TDS? Accordingly, we have heard Advocate Parchure for the Department Advocate Dewani for assessee. We find that the provision for educational facilities is being made by assessee as a part of its obligation under various National Coal Wage Agreement (NCWA), which are legally enforceable in terms of Section 18 of the Industrial Dispute Act. The said provision is also accepted

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE-1, KHAMMAM

In the result, assessee’s appeals for the A

ITA 284/HYD/2024[2016-17]Status: DisposedITAT Hyderabad12 Jun 2025AY 2016-17

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:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

TDS? Accordingly, we have heard Advocate Parchure for the Department Advocate Dewani for assessee. We find that the provision for educational facilities is being made by assessee as a part of its obligation under various National Coal Wage Agreement (NCWA), which are legally enforceable in terms of Section 18 of the Industrial Dispute Act. The said provision is also accepted

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

In the result, assessee's appeals for the A

ITA 286/HYD/2024[2020-21]Status: DisposedITAT Hyderabad12 Jun 2025AY 2020-21
For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 194Section 32ASection 37Section 40Section 40A(9)

TDS?\nAccordingly, we have heard Advocate Parchure for the\nDepartment Advocate Dewani for assessee. We find that the\nprovision for educational facilities is being made by assessee\nas a part of its obligation under various National Coal Wage\nAgreement (NCWA), which are legally enforceable in terms\nof Section 18 of the Industrial Dispute Act. The said\nprovision is also accepted

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

ITA 1179/HYD/2025[2015-16]Status: DisposedITAT Hyderabad21 Jan 2026AY 2015-16
Section 142(1)Section 143(3)Section 263Section 36(1)(iii)Section 36(1)(va)Section 41(1)Section 68

TDS under Section 37(1) of the\nAct. Thus, we are inclined to uphold the findings of the learned\nCIT(A) and reject the ground taken by the assessee.\n20. The next issue that came up for our consideration from\nground no. 5 of the assessee's appeal is disallowance of interest\nexpenditure under Section

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

ITA 882/HYD/2014[2007-08]Status: DisposedITAT Hyderabad20 May 2021AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47

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

ITA 880/HYD/2014[2006-07]Status: DisposedITAT Hyderabad20 May 2021AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47

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

ITA 879/HYD/2014[2005-06]Status: DisposedITAT Hyderabad20 May 2021AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47

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

ITA 803/HYD/2014[2010-11]Status: DisposedITAT Hyderabad20 May 2021AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47

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

ITA 519/HYD/2016[2004-05]Status: DisposedITAT Hyderabad20 May 2021AY 2004-05

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47

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

ITA 802/HYD/2014[2009-10]Status: DisposedITAT Hyderabad20 May 2021AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47

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

ITA 884/HYD/2014[2008-09]Status: DisposedITAT Hyderabad20 May 2021AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47

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

ITA 801/HYD/2014[2006-07]Status: DisposedITAT Hyderabad20 May 2021AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

For Appellant: Shri M.V. Anil KumarFor Respondent: Smt. Anjala Sahu &
Section 143(3)Section 35ESection 43B

TDS of Rs4,08,954 under section 194C of the Income Tax Act from the total expenditure of Rs.2,08,88,541 relating to can outwards, labour charges, car hire charges, security charges, advertisement and office decoration charges. However, deduction was made only of Rs.1,61,856 resulting in short deduction of rupees 2,47