DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

46 I.T.A. Nos.831/H/2015 to 836/H/2015 and 298/Viz/2016 I.T.A.Nos.864/H/2015 to 869/H/2015 and 334/Viz/2016. M/s Annapurna Business Solutions, Hyderabad the original agreement was submitted to the STPI at the time of registration and subsequently copy of agreement was prepared only for renewal of licence. As discussed the copy of agreement was available in the seized material in soft form. The department

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

10. From the reading of Explanation 2A extracted above, it is patently clear that the written down value of the transferred capital asset to the amalgamated company would be the same as it would have been if the amalgamating company continue to hold the capital asset for the purpose of its business. The statutory provision makes it clear that

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NCL GREEN HABITATS PRIVATE LIMITED, HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

46[(h) by way of transaction not regarded as transfer under clause (vicb) or clause (vid) or clause (vii) of section 47.] (f) "stamp duty value" means the value adopted or assessed or assessable by any authority of the Central Government or a State Government for the purpose of payment of stamp duty in respect of an immovable property

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022

depreciation disallowed in the previous year. 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 of penalty under Section 270A

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

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

In the result, appeal ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 32(1)(ii) of the Act. Accordingly, the Assessing Officer disallowed the entire revenue expenditure debited in the P & L A/c and has allowed 25% of depreciation on the said expenditure and balance amount of Rs.106,95,46,203/- has been disallowed and added back to the total income of the appellant company. 15. On appeal, the learned

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

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

section 43B.” Instead, the assessee inadvertently mentioned Rs.914,10,56,673/-, which was the net figure after reducing the allowable payment of Rs.1,07,15,618/-. It was thus argued that this was merely an inadvertent reporting error in the ITR form, without any effect on the taxable income of the ITA Nos.285 & 307/Hyd/2024 24 assessee. The Ld. AR emphasized

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

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

section 43B.” Instead, the assessee inadvertently mentioned Rs.914,10,56,673/-, which was the net figure after reducing the allowable payment of Rs.1,07,15,618/-. It was thus argued that this was merely an inadvertent reporting error in the ITR form, without any effect on the taxable income of the ITA Nos.285 & 307/Hyd/2024 24 assessee. The Ld. AR emphasized