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:

gains of business or profession" of any previous year.] 17. Firstly, we will deal with the issue under Section 32(1)(iia) of the Act. A bare reading of the said provision, make it abundantly clear that in case, any new machinery or plant (other than ships and aircraft), acquired and installed after 31.03.2005 by an assessee engaged

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:

gains of business or profession" of any previous year.] 17. Firstly, we will deal with the issue under Section 32(1)(iia) of the Act. A bare reading of the said provision, make it abundantly clear that in case, any new machinery or plant (other than ships and aircraft), acquired and installed after 31.03.2005 by an assessee engaged

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:

gains of business or profession" of any previous year.] 17. Firstly, we will deal with the issue under Section 32(1)(iia) of the Act. A bare reading of the said provision, make it abundantly clear that in case, any new machinery or plant (other than ships and aircraft), acquired and installed after 31.03.2005 by an assessee engaged

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:

gains of business or profession" of any previous year.] 17. Firstly, we will deal with the issue under Section 32(1)(iia) of the Act. A bare reading of the said provision, make it abundantly clear that in case, any new machinery or plant (other than ships and aircraft), acquired and installed after 31.03.2005 by an assessee engaged

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

capital expenditure in accordance with our observation made as above after providing an opportunity of being heard to the assessee. Accordingly, we allow this ground of the assessee for statistical purpose. 9.5 Hence the Ground No.5 of the assessee is allowed for statistical purpose. 10. Ground No.6 of the assessee relates to excluding the gross amount of foreign exchange gain

GRANULES INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

1) of the Act, dated 21.11.2017 and called upon the assessee to explain as to why the deduction claimed under section 10B of the Act in respect of foreign exchange gain on capital

MARRI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

CMR ENGINEERING EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

NETENRICH TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

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

Bench: SHRI MANJUNATHA G. (Accountant Member), SHRI K.NARASIMHA CHARY (Judicial Member)

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B on or before due date provided under the Act. 4. A search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in the Malla Reddy Group of Institutions on 22.11.2022, including the appellant society premises in which certain loose sheets in the form of application forms, daily statements, excel sheets etc., were found and seized