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

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

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

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

In the result, appeal of the Assessee is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

200 basis points i.e., 3.2%, as an arm's length interest on CCD on ad hoc basis and in complete violation of transfer pricing provisions and the Hon'ble DRP has further erred in upholding the action of Ld. TPO/AO. 1.4 That on the facts and in the circumstances of the case and in law, the Ld. TPO/Ld

DCIT., CIRCLE-3(1), HYDERABAD vs. SARVEJANA HEALTHCARE PVT. LTD., HYDERABAD

In the result, the appeal of the Revenue in ITA No 1511/Hyd/2025 is partly allowed for statistical purposes

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1406 & 1511/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17 & 2020-21) Dy. Cit Vs. Sarvejana Healthcare Circle 3(1) Private Limited, Hyderabad Hyderabad Pan: Aamcs6700Q राज" व "ारा/Revenue By: Smt.U.Mini Chandran,Cit(Dr) िनधा""रती "ारा/Assessee By: C.A. Satya Dinakar सुनवाई की तारीख/Date Of Hearing: 24/03/2026 घोषणा की तारीख/Pronouncement: 08/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

depreciation on goodwill, Rs.50,38,59,200/- as income from other sources under section 56(2)(vii)(b) of the Act and Rs.65

DCIT., CIRCLE-3(1), HYDERABAD vs. SARVEJANA HEALTHCARE PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue in ITA No 1511/Hyd/2025 is partly allowed for statistical purposes

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1406 & 1511/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17 & 2020-21) Dy. Cit Vs. Sarvejana Healthcare Circle 3(1) Private Limited, Hyderabad Hyderabad Pan: Aamcs6700Q राज" व "ारा/Revenue By: Smt.U.Mini Chandran,Cit(Dr) िनधा""रती "ारा/Assessee By: C.A. Satya Dinakar सुनवाई की तारीख/Date Of Hearing: 24/03/2026 घोषणा की तारीख/Pronouncement: 08/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

depreciation on goodwill, Rs.50,38,59,200/- as income from other sources under section 56(2)(vii)(b) of the Act and Rs.65

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. LAURUS LABS LIMITED, VISAKHAPATNAM

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

depreciation. Assessee claimed investment allowance under section 32AD of the Income Tax Act, 1961 (“the Act”). Assessee further claimed weighted deduction in respect of clinical trials at 200

LAURUS LABS LIMITED,VISHAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

depreciation. Assessee claimed investment allowance under section 32AD of the Income Tax Act, 1961 (“the Act”). Assessee further claimed weighted deduction in respect of clinical trials at 200

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. LAURUS LABS LIMITED, VISAKHAPATNAM

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

depreciation. Assessee claimed investment allowance under section 32AD of the Income Tax Act, 1961 (“the Act”). Assessee further claimed weighted deduction in respect of clinical trials at 200

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. LAURUS LABS LIMITED, VISAKHAPATNAM

In the result, ITA No.121/Hyd/2024 is allowed and ITA Nos

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 201, 202 & 203/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17, 2017-18 & 2018-19) Asst.Commissioner Of Laurus Labs Limited Income Tax Vs. Visakhapatnam Circle-5(1), Hyderabad [Pan : Aabcl1170C] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent आ.अपी.सं / Ita No. 121/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2016-17 ) Laurus Labs Limited Asst.Commissioner Visakhapatnam Vs. Of Income Tax [Pan : Aabcl1170C] Circle-16(1) Hyderabad अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

depreciation. Assessee claimed investment allowance under section 32AD of the Income Tax Act, 1961 (“the Act”). Assessee further claimed weighted deduction in respect of clinical trials at 200

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

Depreciation, in respect of the said asset as provided u/s. 35(2)(iv) of the Act as it will lead to double deduction which is not permissible under the law. Ld. DRs reliance on section 35 and 32 of the Act cannot be equated with the deduction allowable under Chapter VIA of the Act. With respect to the facts

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

Depreciation, in respect of the said asset as provided u/s. 35(2)(iv) of the Act as it will lead to double deduction which is not permissible under the law. Ld. DRs reliance on section 35 and 32 of the Act cannot be equated with the deduction allowable under Chapter VIA of the Act. With respect to the facts

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

depreciation and allowances are dealt with in Section 32. Therefore, Parliament has used the expression "any expenditure" in Section 37 to cover both. Therefore, the expression "expenditure" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket

M/S. COUNTRY CLUB INDIA LTD.,,HYDERABAD vs. ACIT, CIRCLE-1(2), HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

depreciation and allowances are dealt with in Section 32. Therefore, Parliament has used the expression "any expenditure" in Section 37 to cover both. Therefore, the expression "expenditure" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket

M/S COUNTRY CLUB INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(2), HYDERABAD, HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmancountry Club Hospitality & Vs Dy. Commissioner Of Income Holidays Ltd (Formerly Tax, Circle 3 (2) Known As Country Club Hyderabad India Ltd) Hyderabad Pan: Aaacc8276B (Appellant) (Respondent)

depreciation and allowances are dealt with in Section 32. Therefore, Parliament has used the expression "any expenditure" in Section 37 to cover both. Therefore, the expression "expenditure" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket

DY.CIT, CIR-1(2), HYDERABAD vs. M/S CUNTRY CLUB (I) LIMITED,, HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

depreciation and allowances are dealt with in Section 32. Therefore, Parliament has used the expression "any expenditure" in Section 37 to cover both. Therefore, the expression "expenditure" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket

ASST. COMMISSIONER OF INCOME TAX CIRCLE-1,, KHAMMAM vs. M/S SINGARENI COLLERIES COMPANY LTD.,, KHAMMAM DIST

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

depreciation after completion and on commencement of its use for business. But since that stage is not reached-no asset having come into existence-the capital-work-in-progress had to be written off as such." 10 I.T.A. No. 802/H/14 and others Singarerni Colleries Companly Ltd., Kothagudem 9. There was no challenge to such finding on facts before the learned

DCIT, CIRCLE-1, KHAMMAM, KHAMMAM vs. THE SINGARENI COLLERIES COMPANY LT.D, KOTHAGUDEM, KOTHAGUDEM

In the result, both the appeals of the revenue for AYs 2009-10 & 2010-11 are dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

depreciation after completion and on commencement of its use for business. But since that stage is not reached-no asset having come into existence-the capital-work-in-progress had to be written off as such." 10 I.T.A. No. 802/H/14 and others Singarerni Colleries Companly Ltd., Kothagudem 9. There was no challenge to such finding on facts before the learned