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:

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

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:

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

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:

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 LIMITED, KOTHAGUDEM

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

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

In the result, assessee's appeals for the A

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

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, it seems to be that the assessee is a subcontractor handling the works on contractual agreement and it is known that deduction u/ s 80IA is not eligible for contractors. Therefore, the assessee has filed revised return and claimed deduction u/s 80IA as an afterthought. It is confirmed from the unsecured loans that all are mobilization advances

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, it seems to be that the assessee is a subcontractor handling the works on contractual agreement and it is known that deduction u/ s 80IA is not eligible for contractors. Therefore, the assessee has filed revised return and claimed deduction u/s 80IA as an afterthought. It is confirmed from the unsecured loans that all are mobilization advances

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

In the result, all the appeals of the assessee for the\nA

section 148 of the\nIncome Tax Act, 1961\nImproper many\nis covered w/1149(1)(b).\nIsame of motive of/5148\nis ayyun.\nDate: 6/10/23\n(SANJAY BAHADUR, IRS)\nDirector General of Income Tax (Inv).\nHyderabad.\n5.\nThus, it is clear that an identical sanction was granted\nby the DGIT (Inv), Hyderabad for all the A.Ys.\n6.\nAt the outset, we note

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

In the result, all the appeals of the assessee for the\nA

Section 148 is bad in law.\n8. On the facts and circumstance of the case, Learned CIT(A)\nis not justified in sustaining the addition of Rs.46,06,858/ -.\n9. Any other ground or grounds that may be urged at the\ntime of hearing of the appeal.”\n\n3.\nWe have considered the rival contentions as well as the\nrelevant

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

In the result, all the appeals of the assessee for the\nA

section 148 of the\nIncome Tax Act, 1961\n(YOGESH KUMAR VERMA, IRS)\nPrincipal Commissioner of Income Tax (Central),\nHyderabad.\nDate: 6/10/23\n(SANJAY BAHADUR, IRS)\nDirector General of Income Tax (Inv).\nHyderabad.\n5. Thus, it is clear that an identical sanction was granted by the DGIT (Inv), Hyderabad for all the A.Ys.\n6. At the outset, we note that

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

In the result, all the appeals of the assessee for the\nA

Section 148 is bad in law.\n8. On the facts and circumstance of the case, Learned CIT(A) is not justified in sustaining the addition of Rs.46,06,858/ -.\n9. Any other ground or grounds that may be urged at the time of hearing of the appeal.”\n\n3.\nWe have considered the rival contentions as well as the relevant

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee for the A

73,38,438\n\n2018-19\n9,79,67,978\n6,83,45,676\n\n2019-20\n3,78,69,796\n2,64,19,212\n\n2020-21\n5,95,94,164\n4,15,74,845\n\n2021-22\n3,00,82,983\n2,09,86,875\n\n2022-23\n114,26,53,017\n85,36,56,501\n\n2023

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(1) , HYDERABAD vs. S A BUILDERS AND DEVELOPERS , HYDERABAD

The appeals of the Revenue are dismissed

section 153A is bad in law, the\nassessment has no leg to stand and the same is required to be\nquashed.\n10. Without prejudice to above legal contention the appellant\ncontends that following additions are liable to be deleted on\nmerits.\n(i)\nCreditors Appearing under Loans &\nAdvances (Asset)\nRs.1,44,86,500\nSl.No.\nName of the Customer\nClosing Balance

S A BUILDERS & DEVELOPERS ,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-1(2) , HYDERABAD

In the result, Ground Nos

section 153A is bad in law, the\nassessment has no leg to stand and the same is required to be\nquashed.\n10. Without prejudice to above legal contention the appellant\ncontends that following additions are liable to be deleted on\nmerits.\n(i)\nCreditors Appearing under Loans &\nAdvances (Asset)\nRs.1,44,86,500\nSl.No.\nName of the Customer\nClosing Balance

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee for the A

section 149(1) of the\nAct, as existed at the relevant point of time and submitted that\nthe asset which include immovable property being land or\nbuilding or both, shares and securities, loans & advances,\ndeposits in the bank account. In support of his contention he has\nrelied upon the judgment of the Hon'ble Delhi High Court in case

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

1, Hyderabad (\"learned TPO\") have:\nGENERAL\n1. erred in determining the income of the Appellant at INR 31,99,82,158 as against returned income\nof INR 28,40,73,030 for the year under consideration.\nVALIDITY OF FINAL ORDER PASSED BEYOND TIMELINES PRESCRIBED UNDER SECTION 153\nOF THE ACT\n2. erred in not passing the final assessment order within

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

TDS), and other similar payments are allowable expenditures under section 37(1) of the Income Tax Act and are compensatory in nature and he has drawn our attention to section 50 of the GST Act which provides as under : “Section 50- Interest on delayed payment of tax.- (1) Every person who is liable to pay tax in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

73,21,403/- Interest u/s 234B 29,229/- Interest u/s 234C Interest u/s 234D 0 Interest u/s 234F 0 1,37,65,576/- Total Interest 2,07,38,340/- Total tax +Interest = Less: TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

73,21,403/- Interest u/s 234B 29,229/- Interest u/s 234C Interest u/s 234D 0 Interest u/s 234F 0 1,37,65,576/- Total Interest 2,07,38,340/- Total tax +Interest = Less: TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued