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:

10 of 17 Coromandel International Limited Vs. DCIT was no consistent accounting principle was adopted in the earlier year. In these circumstances, we are of the considered view that the assessee cannot at the appellate stage seek to introduce such asset into the depreciation framework for the first time. Therefore, we find no infirmity in the order

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.

31 Hinduja National Power Corporation Ltd. (d) any vehicle; or (e) any plant or machinery, the whole of the actual cost of which is allowed as deduction (whether by way of depreciation or otherwise) in computing the income chargeable under the head “Profits and gains of business or profession” of any previous year.] 17. Firstly, we will deal with

DCIT., CIRCLE-8(1), HYDERABAD vs. DBS TECHNOLOGY SERVICES INDIA PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Deputy Commissioner Of Vs. M/S. Dbs Technology Income Tax, Services India Private Circle – 8(1), Limited, Hyderabad. Hyderabad. Pan : Aafcd5584N (Appellant) (Respondent) C.O.No.2/Hyd/2023 Assessment Year 2019-20 Dbs Technology Services India Vs. Deputy Commissioner Of Private Limited, Income Tax, Circle – 8(1), Hyderabad. Hyderabad. Pan : Aafcd5584N (Cross Objector / (Appellant/Revenue) Respondent) Assessee By: Sri M. P. Lohia, C.A. Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 11.07.2023 Date Of Pronouncement: 21.07.2023 आदेश / O R D E R Per Laliet Kumar, Jm: The Appeal & Cross-Objection Filed By The Revenue For A.Y. 2019-20 Arise From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi

depreciation u/s 32 along with such ROI, but filed the same before the final assessment order was made. Thus, these decisions support the contention of the appellant. Further, the appellant has submitted that no adjustment can be made unless intimation is given to the appellant about such adjustment. In this case appellant has not been intimated. In view of these

DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD vs. GLOBAL ALUMINIUM PVT. LTD., SECUNDERABAD, SECUNDERABAD

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

depreciation upto 1999-2000 under Section 32 of the Act and only in the year under consideration, it started claiming deduction u/s 31 of the Act. The Tribunal pointed out that the dies and moulds were not plant and machinery, yet the replacement of dies and moulds were not in the nature of installation of machinery in the factory. Such

INCOME TAX OFFICER, WARD-2(2), HYDERABAD vs. GLOBAL ALUMINIUM PRIVATE LIMITED , HYDERABAD

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

depreciation upto 1999-2000 under Section 32 of the Act and only in the year under consideration, it started claiming deduction u/s 31 of the Act. The Tribunal pointed out that the dies and moulds were not plant and machinery, yet the replacement of dies and moulds were not in the nature of installation of machinery in the factory. Such

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD vs. GLOBAL ALUMINIUM PRIVATE LIMITED, SECUNDERABAD

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

depreciation upto 1999-2000 under Section 32 of the Act and only in the year under consideration, it started claiming deduction u/s 31 of the Act. The Tribunal pointed out that the dies and moulds were not plant and machinery, yet the replacement of dies and moulds were not in the nature of installation of machinery in the factory. Such

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

Appeals are dismissed

Bench: Shri S.S. Godara & Shri L.P. Sahu

depreciation upto 1999-2000 under Section 32 of the Act and only in the year under consideration, it started claiming deduction u/s 31 of the Act. The Tribunal pointed out that the dies and moulds were not plant and machinery, yet the replacement of dies and moulds were not in the nature of installation of machinery in the factory. Such

THE ICFAI SOCIETY,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1(1), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2015-16 The Icfai Society, Vs. The Assistant Commissioner Of Income Tax, Hyderabad. (Exemptions), Hyderabad. Pan : Aaajt0214B. (Appellant) (Respondent) Assessee By: Shri S. Ramarao, Advocate. (Appeared Through Virtual Mode) Revenue By: Smt. Th Vijaya Lakshmi, Cit-Dr Date Of Hearing: 30.07.2024 30.07.2024 Date Of Pronouncement:

depreciation which was not charged against income. 10. That the order of the CIT (A) is bad in law and facts in arbitrarily rejecting the condonation of delay petition in filing Form 35 for following reason; The appeal has been already decided on merit through a speaking order. (ii) The CIT (A) rejected the condonation of delay petition after

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

31,255 incurred for efficient running of business and claimed as expenses, are actually capital in nature and depreciation should be claimed on the same. Computation of deduction under section 10A of the Act 6. (a) erred in excluding the gross amount of foreign exchange gain on hedging with forward contracts / marked to market gains

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

depreciation disallowed in the previous year. 7 ITA.Nos.125 & 474/Hyd./2022 Investment allowance under Section 32AD 8. On the facts and circumstances of the case and in law, the Id. AO, under the direction of the Hon'ble DRP, erred in not appreciating that the Appellant ought to be granted investment allowance as per Section 32AD of the Act. Initiation

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

depreciation under Section 32(ia), without revising the\nopening WDV of plant and machinery on account of the amount of\ndepreciation disallowed in the previous year.\nInvestment allowance under Section 32AD\n8. On the facts and circumstances of the case and in law, the Id. AO,\nunder the direction of the Hon'ble DRP, erred in not appreciating\nthat

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

depreciation @ 10% and not " Plant & Machinery".\n(vii) Any other grounds that may be urged at the time of hearing.\nITA No.284/Hyd/2024 A.Y (2016-17)- (Assessee)\n1. Your Appellant submits that the provision of section 40A(9) are not applicable to the\nfacts of the case, being reimbursement/grant of deficit in the actual expenditure\nincurred by schools run by Singareni

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

31 March 2021, contemplated under section 3(1) of TOLA. Resultantly, the authority specified under section 151(i) of the new regime can grant sanction till 30 June 2021. 79. Under Finance Act 2021, the assessing officer was required to obtain prior approval or sanction of the specified authorities at four stages: a. Section 148A(a) to conduct any enquiry

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

10. The learned counsel for the assessee, Shri Percy Perdiwala, Senior Advocate, submitted that, the Ld. PCIT erred in setting aside the assessment order passed by the A.O. under Section 143(3) r.w.s. 143(3A) and 143(3B) dated 15.04.2021, by exercising powers conferred under Section 263 of the Act, even though the assessment order passed

MANJU DUDALA,HYDERABAD. vs. INCOME TAX OFFICER, WARD-11(3), HYDERABAD.

In the result, appeal ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

31 ITA.Nos.654, 665/Hyd./2023 And ITA.Nos.563 & 648/Hyd./2024 advantage within the public policy embedded in Section 27 of the Contract Act, which enjoins a contract in restraint of trade would otherwise be void. Another way of looking at the issue is whether such rights can be treated or transferred - a proposition fully supported by the controlling object clause

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

section 147 / 148 of the Act, the coordinate Bench had held as under : “22. Coming back to our point we have to examine whether protective assessment/addition is possible under section 147 in respect of the same person and for the same period. When a regular assessment is made and later on it comes to the notice of the Assessing Officer

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

In the result, assessee's appeals for the A

depreciation @ 10% and not \" Plant & Machinery\".\n(vii)\nAny other grounds that may be urged at the time of hearing.\nITA No.284/Hyd/2024 A.Y (2016-17)- (Assessee)\n1. Your Appellant submits that the provision of Section 40A(9) are not applicable to the\nfacts of the case, being reimbursement/grant of deficit in the actual expenditure\nincurred by schools run by Singareni

DCIT., CIRCLE 8(1), HYDERABAD vs. EAST INDIA PETROLEUM LIMITED, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.1087/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19) Deputy Commissioner Of Vs. East India Petroleum Income Tax Limited Circle-8(1)(Incharge) Hyderabad Hyderabad [Pan : Aaace4494K] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri H.Srinivasulu, Ar रधजस् व द्वधरध/Revenue By: Ms.M.Narmada, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 16/01/2025 घोर्णध की तधरीख/Date Of 06/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Revenue Is Directed Against Order Dated 19.08.2024 Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre (Nfac), Delhi, Pertaining To A.Y.2018-19. 2. The Brief Facts Of The Case Are That The Assessee, Engaged In The Business Of Providing Terminalling Services To Oil Marketing Companies For Storage Of Bulk Liquid Products Including Fuels Like High Speed Diesel, Motor Spirit, Petroleum

section 31(1)(ii) and 6th proviso, provided therein and after considering the relevant facts held as under : 25 East India Petroleum Limited 26 East India Petroleum Limited 18. The assessee had also relied upon the decision of ITAT Hyderabad Benches in the case of Teksystems Global Services (P) Ltd.(supra), where, the Tribunal has considered an identical issue