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

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

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

45,288\nUtkarsh Star Mitra Mandal\n50,00,000\nSri Sringeri Peetham Charitable Trust\n1,00,000\nSahrudaya Health\n10,00,000\nHyderabad Round Table No.8 Charitable Trust\n6,00,000\nMaha Bodhi Society\n22,50,000\nTotal Donations\n3,77,95,288\nDeduction eligible U/s 80G\n1,88,97,644\nThe assessing officer held that such a deduction

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:

45 of that Act, of any asset by the banking company to the banking institution. (2)Where, in the assessment of the assessee, full effect cannot be given to any allowance under sub-section (1) in any previous year, owing to there being no profits or gains chargeable for that previous year, or owing to the profits or gains chargeable

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:

45 of that Act, of any asset by the banking company to the banking institution. (2)Where, in the assessment of the assessee, full effect cannot be given to any allowance under sub-section (1) in any previous year, owing to there being no profits or gains chargeable for that previous year, or owing to the profits or gains chargeable

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:

45 of that Act, of any asset by the banking company to the banking institution. (2)Where, in the assessment of the assessee, full effect cannot be given to any allowance under sub-section (1) in any previous year, owing to there being no profits or gains chargeable for that previous year, or owing to the profits or gains chargeable

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:

45 of that Act, of any asset by the banking company to the banking institution. (2)Where, in the assessment of the assessee, full effect cannot be given to any allowance under sub-section (1) in any previous year, owing to there being no profits or gains chargeable for that previous year, or owing to the profits or gains chargeable

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

depreciation of Rs. 7,05,18,382/- and profit on sale of investments of Rs. 5,11,09,716/- and the same should be excluded from the taxable income as these do not form part of the taxable income. For these and such other grounds that may urged at the time of hearing, your appellant prays that the relief claimed

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

depreciation of Rs. 7,05,18,382/- and profit on sale of investments of Rs. 5,11,09,716/- and the same should be excluded from the taxable income as these do not form part of the taxable income. For these and such other grounds that may urged at the time of hearing, your appellant prays that the relief claimed

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

depreciation of Rs. 7,05,18,382/- and profit on sale of investments of Rs. 5,11,09,716/- and the same should be excluded from the taxable income as these do not form part of the taxable income. For these and such other grounds that may urged at the time of hearing, your appellant prays that the relief claimed

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

depreciation of Rs. 7,05,18,382/- and profit on sale of investments of Rs. 5,11,09,716/- and the same should be excluded from the taxable income as these do not form part of the taxable income. For these and such other grounds that may urged at the time of hearing, your appellant prays that the relief claimed

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

depreciation of Rs. 7,05,18,382/- and profit on sale of investments of Rs. 5,11,09,716/- and the same should be excluded from the taxable income as these do not form part of the taxable income. For these and such other grounds that may urged at the time of hearing, your appellant prays that the relief claimed

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

depreciation of Rs. 7,05,18,382/- and profit on sale of investments of Rs. 5,11,09,716/- and the same should be excluded from the taxable income as these do not form part of the taxable income. For these and such other grounds that may urged at the time of hearing, your appellant prays that the relief claimed

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

depreciation of Rs. 7,05,18,382/- and profit on sale of investments of Rs. 5,11,09,716/- and the same should be excluded from the taxable income as these do not form part of the taxable income. For these and such other grounds that may urged at the time of hearing, your appellant prays that the relief claimed

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

45. Under section 36(1)(vii) of the Income-tax Act, 1961, the taxpayer carrying on business is entitled to a deduction, in the computation of taxable profits, of the amount of any debt which is established to have become a bad debt during the previous year, subject to certain conditions. However, a mere provision for bad and doubtful debts

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

45 of that Act, of any asset by the\nbanking company to the banking institution.\n(2)Where, in the assessment of the assessee, full effect\ncannot be given to any allowance under sub-section (1) in\nany previous year, owing to there being no profits or gains\nchargeable for that previous year, or owing to the profits or\ngains

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

In the result, assessee's appeals for the A

45 of that Act, of any asset by the\nbanking company to the banking institution.\n(2)Where, in the assessment of the assessee, full effect\ncannot be given to any allowance under sub-section (1) in\nany previous year, owing to there being no profits or gains\nchargeable for that previous year, or owing to the profits or\ngains

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

45. Under Section 36(1)(vii) of the ITA 1961, the tax payer\ncarrying on business is entitled to a deduction, in the\ncomputation of taxable profits, of the amount of any debt\nwhich is established to have become a bad debt during the\nprevious year, subject to certain conditions. However, a\nmere provision for bad and doubtful debt

PATHFINDER PUBLISHING PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE -16(2), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

45,536/-. The return of income was selected for scrutiny under CASS. During the assessment proceedings, the learned Assessing Officer (“Ld. AO”) noticed that during the F.Y.2016-17, the assessee had issued 3,72,333 equity shares of face value Rs.10/- per share at a premium of Rs.460/- per share. As regards the valuation of shares the assessee opted for discounted

PROGRESSIVE CONSTRUCTIONS LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.625/Hyd/2025 Assessment Year 2021-2022 Progressive Constructions The Dcit, Limited, Hyderabad. Circle-5(1) Vs. Pin – 500 001. Telangana. Hyderabad - 500 004. Pan Aabcp2274M Telangana. (Appellant) (Respondent) Ca Pawan Kumar Chakrapani िनधा"रती "ारा/Assessee By : & Sri Santi Pavan Kumar, Advocate राज" व "ारा/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 02.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

45 PM. It may please be noted that in the absence of any response on the said date, it will be presumed that you have no objection for the proposed revision and suitable orders will be passed on merits as per available records.” 9.1. Thus, the proceedings u/sec.263 of the Act were invoked on the ground that the Assessing Officer