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

13[this section] shall not be admissible for any assessment year beginning on or after the 1st day of April, 2001, unless the assessee furnishes in the prescribed form, 14[***] the report of an accountant, as defined in the Explanation below sub-section (2) of section 28815[before the specified date referred to in section 44AB], certifying that the deduction

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

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

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

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

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

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT 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

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

THE ANDHRA PRADESH STATE CO OPERATIVE BANK LIMITED,HYDERABAD vs. ASST. 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

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

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

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

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

Section 32 ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 37 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) of the IT Act and in the prescribed tables of depreciation ( schedules of the IT rules), the investments in securities by the assesse are not covered. 8.4 We have heard the rival contentions and gone through the record in the light of submissions made

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:

13. In rejoinder, the learned AR of the assessee has submitted that the bills referred by the learned DR are in respect of the escalation claimed by the BHEL and not the original invoice/ bills for the supply of plant & machinery and setting up of the same. He has referred to the certificate issued by the Telangana State Power Coordination

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:

13. In rejoinder, the learned AR of the assessee has submitted that the bills referred by the learned DR are in respect of the escalation claimed by the BHEL and not the original invoice/ bills for the supply of plant & machinery and setting up of the same. He has referred to the certificate issued by the Telangana State Power Coordination

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:

13. In rejoinder, the learned AR of the assessee has submitted that the bills referred by the learned DR are in respect of the escalation claimed by the BHEL and not the original invoice/ bills for the supply of plant & machinery and setting up of the same. He has referred to the certificate issued by the Telangana State Power Coordination

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:

13. In rejoinder, the learned AR of the assessee has submitted that the bills referred by the learned DR are in respect of the escalation claimed by the BHEL and not the original invoice/ bills for the supply of plant & machinery and setting up of the same. He has referred to the certificate issued by the Telangana State Power Coordination

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

13(1)\nHyderabad\n(Appellant)\nSingareni Collieries\nCompany Limited\nKothagudem\nPAN:AAACT8873F\n(Respondent)\nनिर्धारिती द्वारा / Assessee by: Shri M.V.Anil Kumar, Advocate\nराजस्व द्वारा / Revenue by:: Shri B Balakrishna, CIT (DR)\nसुनवाई की तारीख / Date of hearing: 10/06/2025\nघोषणा की तारीख / Pronouncement: 12/06/2025\nआदेश/ORDER\nPer Bench:\nThese 3 sets of cross appeals filed by the assessee as\nwell

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

13) of the Act passed by Assessment Unit, Income-tax Department, pursuant to invalid directions passed by Hon'ble DRP, is illegal; thus making the final assessment order bad in law, null and void and so liable to be quashed. Grounds relating to Transfer Pricing ("TP") 3. On the facts and in the circumstances of the case

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

In the result, assessee's appeals for the A

13(1)\nHyderabad\nSingareni Collieries\nCompany Limited\nKothagudem\nPAN:AAACT8873F\n(Appellant)\n(Respondent)\nनिर्धारिती द्वारा / Assessee by: Shri M.V.Anil Kumar, Advocate\nराजस्व द्वारा / Revenue by:: Shri B Balakrishna, CIT (DR)\nसुनवाई की तारीख / Date of hearing: 10/06/2025\nघोषणा की तारीख / Pronouncement: 12/06/2025\nआदेश/ORDER\nPer Bench:\nThese 3 sets of cross appeals filed by the assessee as\nwell

UNION BANK OF INDIA (ERSTWHILE-ANDHRA BANK),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

depreciation on investments by considering earlier years opening stock and closing balances. ITA Nos.193 & 316/Hyd/2019 4 5.1 The learned Commissioner of Income Tax (Appeals) failed to appreciate the fact that the investments of the appellant bank are stock in trade and the appellant bank is eligible to claim the loss arising out of the valuation of the stock at cost

UNION BANK OF INDIA (ERSTWHILE- ANDHRA BANK),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

13% which was under further negotiations. Since the five-month period in the financial year 2012-13 relevant to A.Y.2013-14 was covered by such settlement, the assessee has made provision of Rs.50,00,00,000/- in the account for the F.Y.2012-13 towards wage revision which was under negotiation. In our considered view, it is an admitted fact that

UNION BANK OF INDIA,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

13% which was under further negotiations. Since the five-month period in the financial year 2012-13 relevant to A.Y.2013-14 was covered by such settlement, the assessee has made provision of Rs.50,00,00,000/- in the account for the F.Y.2012-13 towards wage revision which was under negotiation. In our considered view, it is an admitted fact that

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD vs. ANDHRA BANK , HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

13% which was under further negotiations. Since the five-month period in the financial year 2012-13 relevant to A.Y.2013-14 was covered by such settlement, the assessee has made provision of Rs.50,00,00,000/- in the account for the F.Y.2012-13 towards wage revision which was under negotiation. In our considered view, it is an admitted fact that