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

E-assessment Scheme, 2019, for verifying multi-facet issues, viz. (i). disallowance under section 14A of the Act; (ii). allowability of the assessee's claim for deduction under section 80G in respect of CSR donations; (iii). eligibility of the assessee's claim for deduction under section 80-IA of the Act w.r.t its power generation units; and (iv). addition under

NAGABHUSHANAM VEMULURI, HYDERABAD,HYDERABAD vs. ACIT,CIRCLE-2(1), HYDERABAD

In the result, both the appeals of the assessees’ are partly allowed

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahuassessment Year: 2006-07 Rajendra Kumar Vemuluri, Vs. Asst. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1), Pan – Abipv 2940B Hyderabad. (Appellant) (Respondent) Assessment Year: 2006-07 Nagabhushanam Vemuluri, Vs. Asst. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1), Pan – Abipv 2941A Hyderabad. (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By Shri Sunil Kumar Pandey Date Of Hearing: 25/02/2021 Date Of Pronouncement: 20/04/2021

section 2(22)(e) of the Act, the AO held that as the assessee is having substantial interest in M/s Kalanikethan Textiles and Jewels Pvt. Ltd., i.e. more than 10% shareholding, the amount withdrawn of Rs. 28,52,612/- from the above company over and above his credit balance, is treated as deemed dividend u/s 2(22)(e

RAJENDRA KUMAR VEMULURI, HYDERABAD,HYDERABAD vs. ACIT,CIRCLE-2(1) HYDERABAD, HYDERABAD

In the result, both the appeals of the assessees’ are partly allowed

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahuassessment Year: 2006-07 Rajendra Kumar Vemuluri, Vs. Asst. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1), Pan – Abipv 2940B Hyderabad. (Appellant) (Respondent) Assessment Year: 2006-07 Nagabhushanam Vemuluri, Vs. Asst. Commissioner Of Hyderabad. Income-Tax, Circle – 2(1), Pan – Abipv 2941A Hyderabad. (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By Shri Sunil Kumar Pandey Date Of Hearing: 25/02/2021 Date Of Pronouncement: 20/04/2021

section 2(22)(e) of the Act, the AO held that as the assessee is having substantial interest in M/s Kalanikethan Textiles and Jewels Pvt. Ltd., i.e. more than 10% shareholding, the amount withdrawn of Rs. 28,52,612/- from the above company over and above his credit balance, is treated as deemed dividend u/s 2(22)(e

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

E-assessment Scheme, 2019,\nfor verifying multi-facet issues, viz. (i). disallowance under section 14A\nof the Act; (ii). allowability of the assessee's claim for deduction under\nsection 80G in respect of CSR donations; (iii). eligibility of the\nassessee's claim for deduction under section 80-IA of the Act w.r.t its\npower generation units; and (iv). addition under

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

22 as\nunder:\n“15.\nA perusal of Rule 11UA(2) would indicate that the\nassessee is enabled to determine the FMV of the unquoted equity\nshares either in accordance with the formula prescribed in clause\n(a) or on the basis of a report drawn by a merchant banker who\nmay have determined

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

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

22 as\nunder:\n“15.\nA perusal of Rule 11UA(2) would indicate that the\nassessee is enabled to determine the FMV of the unquoted equity\nshares either in accordance with the formula prescribed in clause\n(a) or on the basis of a report drawn by a merchant banker who\nmay have determined

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

22 as\nunder:\n“15.\nA perusal of Rule 11UA(2) would indicate that the\nassessee is enabled to determine the FMV of the unquoted equity\nshares either in accordance with the formula prescribed in clause\n(a) or on the basis of a report drawn by a merchant banker who\nmay have determined

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:

E of Sub-Section 2 of Section 115WB, sub-clause (i) it also clearly excludes expenses incurred or payments made to fulfill any statutory obligation. So, under both the circumstances i.e. even prior to the amendment to the explanation w.e.f. 01.04.2009, the expenditure incurred towards the supply of electricity by the appellant to its employees would be excluded

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:

E of Sub-Section 2 of Section 115WB, sub-clause (i) it also clearly excludes expenses incurred or payments made to fulfill any statutory obligation. So, under both the circumstances i.e. even prior to the amendment to the explanation w.e.f. 01.04.2009, the expenditure incurred towards the supply of electricity by the appellant to its employees would be excluded

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:

E of Sub-Section 2 of Section 115WB, sub-clause (i) it also clearly excludes expenses incurred or payments made to fulfill any statutory obligation. So, under both the circumstances i.e. even prior to the amendment to the explanation w.e.f. 01.04.2009, the expenditure incurred towards the supply of electricity by the appellant to its employees would be excluded

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:

E of Sub-Section 2 of Section 115WB, sub-clause (i) it also clearly excludes expenses incurred or payments made to fulfill any statutory obligation. So, under both the circumstances i.e. even prior to the amendment to the explanation w.e.f. 01.04.2009, the expenditure incurred towards the supply of electricity by the appellant to its employees would be excluded

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

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

22,20,767 4,96,48,95,860 9,25,06,020 2 State Govt. Dated Securities 4,70,30,66,000 4,74,73,28,272 4,90,43,28,200 2,36,30,867 3 Trustee Securities 2,33,00,00,000 23,00,00,000 24,94,53,250 0 4 Bonus Non Approved Securities 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

22,20,767 4,96,48,95,860 9,25,06,020 2 State Govt. Dated Securities 4,70,30,66,000 4,74,73,28,272 4,90,43,28,200 2,36,30,867 3 Trustee Securities 2,33,00,00,000 23,00,00,000 24,94,53,250 0 4 Bonus Non Approved Securities 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

22,20,767 4,96,48,95,860 9,25,06,020 2 State Govt. Dated Securities 4,70,30,66,000 4,74,73,28,272 4,90,43,28,200 2,36,30,867 3 Trustee Securities 2,33,00,00,000 23,00,00,000 24,94,53,250 0 4 Bonus Non Approved Securities 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

22,20,767 4,96,48,95,860 9,25,06,020 2 State Govt. Dated Securities 4,70,30,66,000 4,74,73,28,272 4,90,43,28,200 2,36,30,867 3 Trustee Securities 2,33,00,00,000 23,00,00,000 24,94,53,250 0 4 Bonus Non Approved Securities 2

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

22,20,767 4,96,48,95,860 9,25,06,020 2 State Govt. Dated Securities 4,70,30,66,000 4,74,73,28,272 4,90,43,28,200 2,36,30,867 3 Trustee Securities 2,33,00,00,000 23,00,00,000 24,94,53,250 0 4 Bonus Non Approved Securities 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

22,20,767 4,96,48,95,860 9,25,06,020 2 State Govt. Dated Securities 4,70,30,66,000 4,74,73,28,272 4,90,43,28,200 2,36,30,867 3 Trustee Securities 2,33,00,00,000 23,00,00,000 24,94,53,250 0 4 Bonus Non Approved Securities 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

22,20,767 4,96,48,95,860 9,25,06,020 2 State Govt. Dated Securities 4,70,30,66,000 4,74,73,28,272 4,90,43,28,200 2,36,30,867 3 Trustee Securities 2,33,00,00,000 23,00,00,000 24,94,53,250 0 4 Bonus Non Approved Securities 2