YERRAM VENKATA SUBBA REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

depreciation of Rs. 5,47,59,555/- claimed by the assessee was allowed, even though the assessee was having taxable income for the asst. years 2011-12 and 2012-13. (iii) Assessee has sold land during the financial year for a consideration of Rs.3,56,25,000/- on which capital gains of Rs. 2,15,93,863/- was offered. However

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.

2 of section 43(6) of Act. Hence, the VITP Pvt. Ltd. claimed excess WDV of Rs.56,78,75,869/-. This excess WDV resulted in excess claim of depreciation of Rs.3,37,71,787/- in AY 2017- 18 with a tax effect of Rs.1,76,48,487 including interest u/s 234B. The balance excess WDV of Rs.53

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:

depreciation that would have been Page 14 of 17 Coromandel International Limited Vs. DCIT allowable had the amalgamation not taken place. Therefore, in case of amalgamation, the facts whether the case of amalgamation falls within the specified condition prescribed under section 47(vii) of the Act as well as under Explanation 2

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 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

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

K LAXMA REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

14) of section 2 27. A perusal of the above shows that the shares are to be valued as per the provisions contained in Rule 11UA of the I.T. Rules, 1961 in accordance with the explanation which read as under: “Determination of fair market value. 11UA. [(1)] For the purposes of section 56 of the Act, the fair market value

N JAIVEER REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

14) of section 2 27. A perusal of the above shows that the shares are to be valued as per the provisions contained in Rule 11UA of the I.T. Rules, 1961 in accordance with the explanation which read as under: “Determination of fair market value. 11UA. [(1)] For the purposes of section 56 of the Act, the fair market value

N JAIDEEP REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

14) of section 2 27. A perusal of the above shows that the shares are to be valued as per the provisions contained in Rule 11UA of the I.T. Rules, 1961 in accordance with the explanation which read as under: “Determination of fair market value. 11UA. [(1)] For the purposes of section 56 of the Act, the fair market value

K VIJAYA BHASKAR REDDY ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

14) of section 2 27. A perusal of the above shows that the shares are to be valued as per the provisions contained in Rule 11UA of the I.T. Rules, 1961 in accordance with the explanation which read as under: “Determination of fair market value. 11UA. [(1)] For the purposes of section 56 of the Act, the fair market value

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

2)(iii). 5. The learned Commissioner of Income Tax (Appeals) erred in law and on facts in remanding the issue to the learned Assessing Officer to re-work the 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

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

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 has been correctly claimed in accordance with the provisions of this section. (6) Notwithstanding anything contained in any other provision of this Act, in computing the total income

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:

14. We have considered the rival submissions as well as relevant material available on record. For the A.Y 2015-16, the Assessing Officer has considered this issue in para 10.3 as under: 15. For the A.Y 2016-17 the Assessing Officer apart from disallowing the claim as not falling in the ambit of section 32AC of Page

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:

14. We have considered the rival submissions as well as relevant material available on record. For the A.Y 2015-16, the Assessing Officer has considered this issue in para 10.3 as under: 15. For the A.Y 2016-17 the Assessing Officer apart from disallowing the claim as not falling in the ambit of section 32AC of Page

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:

14. We have considered the rival submissions as well as relevant material available on record. For the A.Y 2015-16, the Assessing Officer has considered this issue in para 10.3 as under: 15. For the A.Y 2016-17 the Assessing Officer apart from disallowing the claim as not falling in the ambit of section 32AC of Page