THE WARANGAL DISTRICT COOPERATIVE CENTRAL BANK LIMITED,HANAMKONDA vs. DCIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.364/Hyd/2023 ("नधा"रण वष"/Assessment Year:2021-22) The Warangal District Vs. Deputy Commissioner Of Cooperative Central Bank Income Tax, Limited, Hanamkonda, Circle-3(1), Warangal. Hyderabad. Pan: Aabtt3137G (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri S. Rama Rao, Advocate राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 11/11/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

condonation of the delay in filing of “Form 10IF”, and that no relief in respect of interest under sections 234A, 234B or 234C shall be admissible, in line with the CBDT order dated 01.09.2025. 14. Apropos the disallowance by the AO of the delayed deposit of the employees share of contribution towards PF/ESI

BSCPL AURANG TOLLWAY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay, wherein it was submitted that the appeal for the relevant assessment year was required to be filed within 60 days from the date of receipt of the order passed under Section 263 of the Income-tax Act, 1961. However, the

163 DTR 321 M/s Ashoka Infrastructure Ltd Vs Asst. CIT.” 3. At the outset, there is a delay of 30 days in filing the present appeal before the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay, wherein it was submitted that the appeal for the relevant assessment year was required to be filed within

RR MARKETING,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

condone the delay involved in the filing of the present\nappeal.\nWe have heard the Learned Authorized Representatives of both\nparties, perused the orders of the lower authorities and the material\navailable on record, as well as considered the judicial pronouncements\nthat have been pressed into service by the Ld. AR to drive home his\ncontentions.\nShri A.V. Raghuram, Advocate

DY. COMMISSIONER OF INCOME TAX , (INTL.TXN)-1, HYDERABAD vs. HSBC HOLDING PLC, LONDON

In the result, Revenue’s appeals are dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

163 days delay in filing before the ITAT. To :- 2 -: ITA Nos. 336 to 339/Hyd/2020 HSBC Holdings PLC, . this effect, the revenue filed an affidavit for condonation of delay wherein it was, inter-alia, affirmed that due to the Global pandemic Covid-19 at the relevant point of time, caused the impugned delay in filing of the instant appeals. Case

DY. COMMISSIONER OF INCOME TAX , (INTL.TXN)-1, HYDERABAD vs. HSBC HOLDING PLC, HYDERABAD

In the result, Revenue’s appeals are dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

163 days delay in filing before the ITAT. To :- 2 -: ITA Nos. 336 to 339/Hyd/2020 HSBC Holdings PLC, . this effect, the revenue filed an affidavit for condonation of delay wherein it was, inter-alia, affirmed that due to the Global pandemic Covid-19 at the relevant point of time, caused the impugned delay in filing of the instant appeals. Case

DY. COMMISSIONER OF INCOME TAX-1, HYDERABAD vs. HSBC HOLDINGS PLC, LONDON

In the result, Revenue’s appeals are dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

163 days delay in filing before the ITAT. To :- 2 -: ITA Nos. 336 to 339/Hyd/2020 HSBC Holdings PLC, . this effect, the revenue filed an affidavit for condonation of delay wherein it was, inter-alia, affirmed that due to the Global pandemic Covid-19 at the relevant point of time, caused the impugned delay in filing of the instant appeals. Case

DY. COMMISSIONER OF INCOME TAX , (INTL.TXN)-1, HYDERABAD vs. HSBC HOLDING PLC, LONDON

In the result, Revenue’s appeals are dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

163 days delay in filing before the ITAT. To :- 2 -: ITA Nos. 336 to 339/Hyd/2020 HSBC Holdings PLC, . this effect, the revenue filed an affidavit for condonation of delay wherein it was, inter-alia, affirmed that due to the Global pandemic Covid-19 at the relevant point of time, caused the impugned delay in filing of the instant appeals. Case

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

DCIT-2, (INTERNATIONAL TAXATION), HYD, HYDERABAD vs. MADHUCON SINO HYDRO JV, HYD, HYDERABAD

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these Cross Objections is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 5. Both the learned representatives next invited our attention to the CIT(A)’s detailed discussion accepting the assessee’s contentions challenging invocation of section 163

SHALINI BHUPAL,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2019-20 Smt.Shalini Bhupal Vs. Dy. C. I. T. Hyerabad Circle 2(1) Pan:Acepb2655G Hyderabad (Appellant) (Respondent) Assessee By: Shri Kumar Pal, Ca Revenue By: Smt. K. Haritha, Dr Date Of Hearing: 02/08/2023 Date Of Pronouncement: 30/08/2023 Order Per R.K. Panda, Vice-This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.03.2022 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2019-20. 2. There Is A Delay Of 2Days In Filing Of This Appeal By The Assessee For Which The Assessee Has Filed A Condonation Petition Along With An Affidavit Explaining The Reasons For Such Delay. After Considering The Contents Of The Condonation Petition Filed Along With The Affidavit, The Delay In Filing Of This Appeal By 2 Days Is Condoned & The Appeal Is Admitted For Adjudication.

condoned and the appeal is admitted for adjudication. Page 1 of 7 ITA 271 of 2023 Shalini Bhupal 3. Although a number of grounds have been raised by the assessee, however, these all relate to the order of the learned CIT (A) NFAC in upholding the order passed u/s 154 of the I.T. Act in which the foreign tax credit

UPAKAR INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. ACIT, CENT CIR-2(4), HYDERABAD

In the result, the appeal of the revenue is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

condoned. 3. The Ld. AR raised an additional ground in all their appeals with regards to the validity of issue of notice u/s. 153C of the Income Tax Act, 1961 ('the Act'). The Ld. AR submitted that, additional ground so filed are admissible in view of judgment rendered by the Hon’ble Supreme Court in the case of National Thermal

UPAKAR INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. ACIT, CENT CIR-2(4), HYDERABAD

In the result, the appeal of the revenue is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

condoned. 3. The Ld. AR raised an additional ground in all their appeals with regards to the validity of issue of notice u/s. 153C of the Income Tax Act, 1961 ('the Act'). The Ld. AR submitted that, additional ground so filed are admissible in view of judgment rendered by the Hon’ble Supreme Court in the case of National Thermal

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, MADHAPUR

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

condone the delay and admit all the appeals for hearing. 3. The grounds of appeal filed by the Revenue in ITA No.682/Hyd/2024 read as under : “1. Both on the fact and in the circumstance of the case, the ld.CIT(A) is not justified in deleting disallowance of Rs. 11,56,60,835/- made u/s 80IA(13). 2. Whether