VINOD AERUKALA ,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(2), HYDERABAD

In the result, the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2012-13 Moola Padmaja Vs. Acit,Cc-3(2) 8-1-293/A/74/A 7Th Floor Dwaraka Nagar Colony Aaykar Bhawan Narayanamma Engineering Basheer Bagh College, Raidurg Hyderabad-500 004 Hyderabad-500 008 Pan : Aoipp2482B Assessment Year: 2012-13 Vinod Aerakula Vs Acit,Cc-3(2) B-109, Western Plaza 7Th Floor Hussain Shahwali Darha Aaykar Bhawan Shaikpet, Hyderabad Basheer Bagh Telangana Hyderabad-500 004 Pan : Aoopa5855R (Appellant) (Respondent) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri K.P.R.R.Murthy, Sr.Ar Date Of Hearing: 15.02.2023 Date Of Pronouncement: 22.02.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): The Above Two Appeals Filed By The Respective Assessees Are Directed Against The Separate Orders Dated 31.03.2022 & 27.3.2022 Respectively Of The Learned Cit(A) (Appeals)-11, Hyderabad Relating To Ay 2012-13. Since Identical Grounds Have Been Raised By The Respective Assessees, Therefore, These Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience.

capital gain in the return of income filed u/s 148 of the 1T Act. 4. The Hon'ble CIT(A) should have considered that this is a case which falls under explanation 1 to section 271 (1) (c) as the appellant had furnished all the particulars necessary for the computation of income was under a bonafide belief

INCOME TAX OFFICER, WARD-1, CHITTOOR vs. G VIJAYASIMHA REDDY, BENGALURU

In the result, the appeal of Revenue in ITA

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

Section 54F of the Income tax Act, 1961. Hence he admitted the income received from the project as capital gains and claimed exemption u/s 54F. For all the above reasons discussed above the request of the assessee vide his letter dated 11.12 2017 received in this office on 15.12.2017 to consider the receipts from the project as capital gains

ACIT, CIRCLE-2(1), HYDERABAD vs. HINDUJA NATIONAL POWER CORPORATION LIMITED, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleआ.अपी.सं / Ita No.235/Hyd/2023 (निर्धारण वर्ा / Assessment Year: 2016-17) The Assistant M/S. Hinduja National Power Commissioner Of Income Vs. Corporation Ltd. Tax, Circle 2(1), Hyderabad. Hyderabad. Pan : Aabch2426D अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Shri K. A. Sai Prasad, C.A. रधजस्‍व द्वधरध/Revenue By: Shri B. Bala Krishna, Cit-Dr.

capital gains on property sales. 3 Hinduja National Power Corporation Ltd. Notices under sections 143(2) and 142(1) of the Act were issued, and the assessee provided necessary financial documents, including audit reports, annual reports, and transaction details. The company entered into international transactions of ₹172.67 crore and Special Domestic Transactions of ₹30.89 crore. The Transfer Pricing Officer determined

NADELLA MUNIKANNAIAH ,TIRUPATI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), TIRUPATI

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 N.Dathri L/R Of Late Vs. Acit, Circle-1(1) Nadella Muni Kannaiah Tirupati C/O. Katrapati & Andhra Pradesh Associates 1-1-298/2/B/3, 1St Floor Ashok Nagar,Street No.1 Hyderabad-500 020

271(1)(C) of the I.T.Act, 1961 4. The learned Commissioner of Income tax (Appeals) is not justified in not considering the fact that the year of taxability of capital gain in the case of Joint Development Agreement is controversial issue 2 ITA 444/Hyd/2019 and this was a reasonable cause for non-disclosure of such capital gain by appellant

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

gains of business\nwhich is not incidental to the attainment of its objectives or separate\nbooks of account are not maintained by such trust or institution in\nrespect of the business which is incidental to the attainment of its\nobjectives; or\n(c) the trust or institution has applied any part of its income from the\nproperty held under

PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

B ‘ Bench, Hyderabad श्री धिजय पाल राि, उपाध्‍यक्ष एिं श्री मंजुनाथ जी, लेखा सदस्‍य के समक्ष । Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha G. Accountant Member आ.अपी.सं /ITA Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. CIT Hyderabad Circle 5(1) PAN:AJQPT7772F Hyderabad (Appellant) (Respondent

PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

B ‘ Bench, Hyderabad श्री धिजय पाल राि, उपाध्‍यक्ष एिं श्री मंजुनाथ जी, लेखा सदस्‍य के समक्ष । Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha G. Accountant Member आ.अपी.सं /ITA Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. CIT Hyderabad Circle 5(1) PAN:AJQPT7772F Hyderabad (Appellant) (Respondent

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)

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in respect of the business which is incidental to the attainment of its objectives; or (c) the trust or institution has applied any part of its income from the ensure for the benefit

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

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

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in respect of the business which is incidental to the attainment of its objectives; or (c) the trust or institution has applied any part of its income from the ensure for the benefit

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:

271 ITR 401) as well as the judgement in the case of Commissioner of Sales Tax, Madhya Pradesh vs. Madhya Pradesh Electricity Board (1969) (SCR)(2) 939. The learned AR has also relied upon the decision of the Chennai Bench of the Tribunal in case of ACIT vs. M. Satish Kumar (33 Taxmann.com 396) and submitted that the process

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:

271 ITR 401) as well as the judgement in the case of Commissioner of Sales Tax, Madhya Pradesh vs. Madhya Pradesh Electricity Board (1969) (SCR)(2) 939. The learned AR has also relied upon the decision of the Chennai Bench of the Tribunal in case of ACIT vs. M. Satish Kumar (33 Taxmann.com 396) and submitted that the process

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:

271 ITR 401) as well as the judgement in the case of Commissioner of Sales Tax, Madhya Pradesh vs. Madhya Pradesh Electricity Board (1969) (SCR)(2) 939. The learned AR has also relied upon the decision of the Chennai Bench of the Tribunal in case of ACIT vs. M. Satish Kumar (33 Taxmann.com 396) and submitted that the process

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:

271 ITR 401) as well as the judgement in the case of Commissioner of Sales Tax, Madhya Pradesh vs. Madhya Pradesh Electricity Board (1969) (SCR)(2) 939. The learned AR has also relied upon the decision of the Chennai Bench of the Tribunal in case of ACIT vs. M. Satish Kumar (33 Taxmann.com 396) and submitted that the process

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)

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in respect of the business which is incidental to the attainment of its objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust

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)

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust for private religious purposes, which does not ensure for the benefit

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)

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust for private religious purposes, which does not ensure for the benefit

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)

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust for private religious purposes, which does not ensure for the benefit

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)

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust for private religious purposes, which does not ensure for the benefit

MARUTHI 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)

gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in respect of the business which is incidental to the attainment of its objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust