ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

14A of\nthe Act, uphold the same. The Grounds of appeal Nos. 1 & 2 raised by\nthe revenue are dismissed.\n14.\nWe shall now take by the grievance of the revenue that the\nCIT(A) has erred in law and facts of the case in vacating the\ndisallowance of the claim of the assesseee company for deduction\nunder section

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

Section 14A of the Act could be made. In this regard, we\nhave gone through the para no. 4 of the order of the Ld. AO, which is to the\nfollowing effect :\n4/1\nIt is observed from the Balance Sheet that the assessee-company has\ninvestments to the tune of Rs.2,43,34,65,000/- as on 31.03.2016. During

CHINTALAPATI HOLDINGS PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

depreciation on building from which rent was earned not to be allowed, disallowance under section 14A of the Act and interest

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

depreciation on building from which rent was earned not to be allowed, disallowance under section 14A of the Act and interest

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

depreciation on building from which rent was earned not to be allowed, disallowance under section 14A of the Act and interest

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

section 14A r.w.r 8D is not applicable when shares are held as stock-in-trade by a Bank. Although we are unable to agree with the said argument of the learned Counsel for the assessee, but to give another opportunity to the assessee to explain its case before the Assessing Officer in light of the decision

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:

section 14A of the Act, while allowing the claim of the assessee on account of depreciation on non-compete fees

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 14A of the Act. " 11.8 In the case of Holcin India (P) Ltd. (supra) the facts were that the respondent- assessee was a subsidiary of Holderind Investments Ltd., Mauritius, which was formed as a holding company for 'making downstream investments in cement manufacturing ventures in India. In the return of income filed for the Assessment Year

LYCOS INTERNET LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

depreciation.\n11. Recompute the cost of asset as per the provisions of section 43A.\n12. Details of investments in share capital (including share application money) made\nduring the year, including the number of shares, face value of the share and price\npaid per share. Also furnish the details of dividends received, if any, during the year.\n13. Quantitative and value

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

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

section 14A r.w.r 8D is not applicable when shares are held as stock-in-trade\nby a Bank. Although we are unable to agree with the said argument of the\nlearned Counsel for the assessee, but to give another opportunity to the assessee\nto explain its case before the Assessing Officer in light of the decision of the\nHon

INCOME TAX OFFICER, WARD-1(3), HYDERABAD vs. BHAGYANAGAR INDIA LIMITED , SECUNDERABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1200/Hyd/2019 (निर्धारण वर्ा/Assessment Year:2016-17) Income Tax Officer, M/S. Bhagyanagar India Ward-1(3), Hyderabad. Vs. Limited, Hyderabad. Pan:Aaacb8963C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.C. Devdas, C.A. रधजस् व द्वधरध/Revenue By: Shri Narender Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 24/07/2025 घोर्णध की तधरीख/Pronouncement: 08/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Hyderabad (“Ld. Cit(A)”), Dated 16.05.2019 For The A.Y. 2016-17. 2. The Revenue Has Raised The Following Grounds Of Appeal:

Section 14A of the Act is directed to be deleted and the order of the Ld. CIT(A) is upheld. 13. As far as the deletion of Rs.2,22,94,090/- is concerned, we have gone through para no.46A of AS-11 which is to the following effect : “ 46A. (1) In respect of accounting periods commencing on or after

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

14A of the Act in light of our discussion given herein above and also by considering the decision of ITAT, Hyderabad benches in assessee’s own case for the A.Y.2012-13 and recompute the disallowance as per law. 38. The next issue that came up for our consideration from Ground No.4 of assessee’s appeal is with regard to the recovery

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

14A of the Act in light of our discussion given herein above and also by considering the decision of ITAT, Hyderabad benches in assessee’s own case for the A.Y.2012-13 and recompute the disallowance as per law. 38. The next issue that came up for our consideration from Ground No.4 of assessee’s appeal is with regard to the recovery

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

14A of the Act in light of our discussion given herein above and also by considering the decision of ITAT, Hyderabad benches in assessee’s own case for the A.Y.2012-13 and recompute the disallowance as per law. 38. The next issue that came up for our consideration from Ground No.4 of assessee’s appeal is with regard to the recovery

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

14A of the Act in light of our discussion given herein above and also by considering the decision of ITAT, Hyderabad benches in assessee’s own case for the A.Y.2012-13 and recompute the disallowance as per law. 38. The next issue that came up for our consideration from Ground No.4 of assessee’s appeal is with regard to the recovery

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

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

14A r.w.r 8D is not applicable when shares are held as stock-in-trade by a Bank. Although we are unable to agree with the said argument of the learned Counsel for the assessee, but to give another opportunity to the assessee to explain its case before the Assessing Officer in light of the decision of the Hon'ble Supreme

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

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

14A r.w.r 8D is not applicable when shares are held as stock-in-trade by a Bank. Although we are unable to agree with the said argument of the learned Counsel for the assessee, but to give another opportunity to the assessee to explain its case before the Assessing Officer in light of the decision of the Hon'ble Supreme

MYLAN LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result. appeal of the Assessee is partly\nallowed for statistical purposes and appeal of Revenue is\npartly allowed for statistical purposes

depreciation on intangible assets, then, a suitable\nadjustment needs to be given for PLI on comparables. In the\npresent case, going by the ratio of tangible fixed assets to\nintangible asset, the appellant company is having high\nproportionate of intangible assets which is almost unique\ngoing by the other comparables. Since there is no details\nwith regard to comparable financial