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:

depreciation under section 32(1) (ii-a) of the Act. As per the settled position of law, an assessee claiming exemption has to strictly and literally comply with the exemption provisions. Therefore, the said decision shall not be applicable to the facts of the case on hand, while considering the exemption provisions. Even otherwise, Chapter III and Chapter

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:

depreciation under section 32(1) (ii-a) of the Act. As per the settled position of law, an assessee claiming exemption has to strictly and literally comply with the exemption provisions. Therefore, the said decision shall not be applicable to the facts of the case on hand, while considering the exemption provisions. Even otherwise, Chapter III and Chapter

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:

depreciation under section 32(1) (ii-a) of the Act. As per the settled position of law, an assessee claiming exemption has to strictly and literally comply with the exemption provisions. Therefore, the said decision shall not be applicable to the facts of the case on hand, while considering the exemption provisions. Even otherwise, Chapter III and Chapter

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

depreciation under section 32(1) (ii-a) of the Act.\nAs per the settled position of law, an assessee claiming\nexemption has to strictly and literally comply with the\nexemption provisions. Therefore, the said decision shall not\nbe applicable to the facts of the case on hand, while\nconsidering the exemption provisions. Even otherwise,\nChapter III and Chapter

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

In the result, assessee's appeals for the A

depreciation under section 32(1) (ii-a) of the Act.\nAs per the settled position of law, an assessee claiming\nexemption has to strictly and literally comply with the\nexemption provisions. Therefore, the said decision shall not\nbe applicable to the facts of the case on hand, while\nconsidering the exemption provisions. Even otherwise,\nChapter III and Chapter

INCOME TAX OFFICER, WARD-1(2), HYDERABAD vs. ATHENA GLOBAL TECHNOLOGIES LIMITED (FORMERLY M/S VJIL CONSULTING LIMITED), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 194A(3)(iii) of the Act, as per which, no TDS is required to be deducted on payment of bank interest and accordingly no disallowance could be made u/s 40(a)(ia) of the Act. Further, in case of disallowance of depreciation

ATHENA GLOBAL TECHNOLOGIES LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(4), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 194A(3)(iii) of the Act, as per which, no TDS is required to be deducted on payment of bank interest and accordingly no disallowance could be made u/s 40(a)(ia) of the Act. Further, in case of disallowance of depreciation

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-8(1), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 194A(3)(iii) of the Act, as per which, no TDS is required to be deducted on payment of bank interest and accordingly no disallowance could be made u/s 40(a)(ia) of the Act. Further, in case of disallowance of depreciation

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

194A of the Act to the impugned payments, and thereafter decide the issue afresh in accordance with law. The assessee shall be afforded reasonable opportunity of being heard. The ground no. 11 of the assessee’s appeal is allowed for statistical purposes. 18. The ground no. 12 of the assessee’s appeal relates to the disallowance of Rs.1

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

194A of the Act to the impugned payments, and thereafter decide the issue afresh in accordance with law. The assessee shall be afforded reasonable opportunity of being heard. The ground no. 11 of the assessee’s appeal is allowed for statistical purposes. 18. The ground no. 12 of the assessee’s appeal relates to the disallowance of Rs.1

ACIT., CIRCLE-1(1), TIRUPATI vs. PONNAMBALAM KRISHNAN, CHITTOOR

In the result, the appeal of the revenue and cross objections of the assessee are partly allowed for statistical purposes in above terms

Bench: Shri Manjunatha G, Accountnat Member & Shri Prakash Chand Yadavआ.अपी.सं /Ita No.655/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2017-18) Asst. Commissioner Of Income Shri Ponnambalam Krishnan, Tax, Circle 1(1), Tirupati. Vs. Ekjambarakuppam, Chittoor, A.P. Pan : Bedpk5641B (Appellant) (Respondent) C.O. No.11/Hyd/2024 (Assessment Year:2017-18) (By Assessee) निर्धाररती द्वधरध/Assessee By: Shri E. Phalguna Kumar, C.A. रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala,Sr-Dr सुिवधई की तधरीख/Date Of 10/09/2024 Hearing: घोर्णध की रीख/Pronouncement: 20/09/2024

section 194A of the Act. There are circulars of CBDT to that effect also. Therefore the view of the CIT(A) restricting the disallowance to the tune of Rs63,860/- i.e. being 30% of Rs.2,12,868/- for failing to deduct TDS on audit fees as well as interest paid on vehicle loan is 9 C.O. No.11/Hyd/2024 a plausible view

PINKI FRESH FOODS LIMITED,CHITTOOR vs. ITO., WARD-1, CHITTOOR

Bench: Us :

section 2(14) of Income Tax Act, 1961" as income from Capital Gain u/s 112. 4. In the facts and circumstances of the case, the learned CIT(A) erred by upholding the addition made by learned assessing officer as the Interest Income of Rs. 2,77,140 as unexplained income though the same was reflected in form 26AS

AP TOURISM DEVELOPMENT CORPORATION LIMITED,VIJAYAWADA vs. DCIT, CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2017-18 A.P Tourism Development Vs. Dy. Cit Corporation Ltd, Circle 1(1) Vijayawada Hyderabad Pan:Aadca9817H (Appellant) (Respondent) Assessee By: Advocate R. Mohan Kumar Revenue By: Shri Kumar Aditya, Dr Date Of Hearing: 24/05/2023 Date Of Pronouncement: 24/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Ex-Parte Order Dated 13/02/2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2017-18. 2. Facts Of The Case, In Brief, Are That The Assessee Is An A.P State Government Corporation Incorporated Under The Companies Act, 1956 & Established With The Main Objective Of Developing Tourism Infrastructure In The State Of Andhra Pradesh. The Corporation Is A State Govt. Company Since 1976. It Filed Its Return Of Income Declaring Total Loss Of Rs.9,95,84,720/-. The Case Was Selected For Scrutiny Under Cass & Statutory Notices U/S 143(2) & 142(1) Were Issued & Delivered Electronically To The Page 1 Of 6

depreciation of Rs.56,04,368/-. The Assessing Officer further noted from the 26AS statement that the assessee has received the following amount during the year: S.No Description of the Section under which TDS Amount of income income received is made by the deductor received 1 Rental/lease 194IB 2,27,57,627 income 2 Interest 194A