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

14. Coming to the Income-tax Act, 1961, there is no express provision to support the contention of Revenue. On the other hand, section 80G(2)(iiihk) and (iiihl) of the Act expressly provide that such sums donated for Swatch Bharath Kosh and Clean Ganga Fund shall be the amounts other than the sums spent by the assessee in pursuance

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

depreciation from an eligible unit were\nset off against other income in previous years, they should not be\nreopened or notionally carried forward again to reduce the Section 801A\ndeduction in the chosen initial assessment year. We find that the “SLP”\nfiled by the revenue against the aforesaid order of the Hon'ble High\nCourt had been dismissed

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

section 56 shall be\nthe value, on the valuation date, of such unquoted equity shares\nas determined in the following manner under clause (a) or clause\n(b), at the option of the assessee, namely:-\n(a) the fair market value of unquoted equity shares=(A-L) x (PV),\n(PE)\nA = book value of the assets in the balance

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

section 56 shall be\nthe value, on the valuation date, of such unquoted equity shares\nas determined in the following manner under clause (a) or clause\n(b), at the option of the assessee, namely:-\n(a) the fair market value of unquoted equity shares=(A-L) x (PV),\n(PE)\nA = book value of the assets in the balance

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

section 56 shall be\nthe value, on the valuation date, of such unquoted equity shares\nas determined in the following manner under clause (a) or clause\n(b), at the option of the assessee, namely:-\n(a) the fair market value of unquoted equity shares=(A-L) x (PV),\n(PE)\nA = book value of the assets in the balance

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

2 of\nsection 43(6) of Act. Hence, the VITP Pvt. Ltd. claimed excess WDV of Rs.56,78,75,869/-.\nThis excess WDV resulted in excess claim of depreciation of Rs.3,37,71,787/- in AY 2017-\n18 with a tax effect of Rs.1,76,48,487 including interest u/s 234B. The balance excess WDV\nof 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 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

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 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 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

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

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

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

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