COROMANDEL INTERNATIONAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

depreciation and the overall depreciation allowable in the year of amalgamation cannot exceed the depreciation that would have been Page

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

depreciation on non-compete fee and depreciation\non Film Software Library and allowed the claim of assessee\ncompany on account

ACIT, CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

depreciation on non-compete fee and depreciation\non Film Software Library and allowed the claim of assessee\ncompany on account

ACIT., CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

depreciation on non-compete fee and depreciation\non Film Software Library and allowed the claim of assessee\ncompany on account

EENADU TELEVISION PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

depreciation on non-compete fee and depreciation\non Film Software Library and allowed the claim of assessee\ncompany on account

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

depreciable asset and has wrongly granted the depreciation over that. He relied upon the following decisions : • ExceleX Bio Polymers (P) Ltd vs. DCIT

VITP PRIVATE LIMITED (IN THE CASE OF FLAGSHIP DEVELOPERS PRIVATE LIMITED),HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.572/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Vitp Private Ltd (In The Vs. Dy. Commissioner Of Case Of Flagship Income Tax, Circle 8(1) Developers (P) (Ltd) Hyderabad Hyderabad Pan:Aaccv2672G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Tanmayee Rajkumar राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 20/11/2024 घोषणा की तारीख/Pronouncement: 02/01/2025 आदेश/Order

depreciation and explained that there is no discrepancy in the depreciation claimed by the assessee while computing the book profit

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

depreciation to the WDV\nof the respective blocks and claimed depreciation on the increased\nWDV,\nwhich resulted in increase in depreciation

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED , HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

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

depreciable: Even if it is presumed that the asset created is 'right to collect toll', the same is not depreciable

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

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

depreciable: Even if it is presumed that the asset created is 'right to collect toll', the same is not depreciable

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

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

depreciable: Even if it is presumed that the asset created is 'right to collect toll', the same is not depreciable

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVAT LIMITED, HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

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

depreciable: Even if it is presumed that the asset created is 'right to collect toll', the same is not depreciable

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED , HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

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

depreciable: Even if it is presumed that the asset created is 'right to collect toll', the same is not depreciable

PRATHIMA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT (EXEMPTIONS) CIRCLE-1(1), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

depreciation only, (ii) allowance of depreciation partly, (iii) allowance of application fully, (iv) allowance of application partly, (v) no depreciation

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.

depreciation of ₹271.70 crore under section 32(1)(iia) was disallowed as the assessee was entitled to depreciation only at 20% for assets

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

depreciation on this and claimed under Profit and loss account. During the year, the appellant has claimed Rs.7,05,18,382/- as depreciation

THE ANDHRA PRADESH STATE COOPERATIVE BANK LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

depreciation on this and claimed under Profit and loss account. During the year, the appellant has claimed Rs.7,05,18,382/- as depreciation

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

depreciation on this and claimed under Profit and loss account. During the year, the appellant has claimed Rs.7,05,18,382/- as depreciation