DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

depreciation should be claimed on the same. Computation of deduction under section 10A of the Act 6. (a) erred in excluding the gross amount of foreign exchange gain on hedging with forward contracts / marked to market gains of Rs. 106,68,32,843 from the export turnover of ITES for the purpose of computing the deduction under section

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

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

37 Tracks & Towers Infratech Pvt.Ltd. (Part IX) that as per the provision of section 80AC filing of return within due date specified u/s 139(1) is mandatory, but there is no stipulation as to claiming deduction in the return of income, as long as, the claim is within due date specified under sub section (5) of section 139, then

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

37 Tracks & Towers Infratech Pvt.Ltd. (Part IX) that as per the provision of section 80AC filing of return within due date specified u/s 139(1) is mandatory, but there is no stipulation as to claiming deduction in the return of income, as long as, the claim is within due date specified under sub section (5) of section 139, then

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

4 to 11 of its order, the\nHon'ble High Court has held as under:\n4.\nIn respect of the claim of depreciation, the assessee had added the\nunabsorbed depreciation of the amalgamating company to the written\ndown value and claimed depreciation on the resultant amount. The\nAssessing Officer allowed depreciation only on the written down\nvalue

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:

4. Disallowance of claim under section 35(2AB) of the Act: a. The Ld. Assessing Officer has grossly erred in disallowing the weighted deduction of INR 2,75,00,000 claimed by the Appellant under Section 35(2AB) of the Act, solely on the basis of a mechanical comparison between the amount stated in Form 3CL issued by the Department

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

37 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd Page 38 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd 31. It was submitted that since the issue has attained finality upto the level of the Tribunal for A.Y.s 2005-06 to 2007-08 and the relief

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

37 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd Page 38 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd 31. It was submitted that since the issue has attained finality upto the level of the Tribunal for A.Y.s 2005-06 to 2007-08 and the relief

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

37 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd Page 38 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd 31. It was submitted that since the issue has attained finality upto the level of the Tribunal for A.Y.s 2005-06 to 2007-08 and the relief

ACIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD vs. NCC LIMITED, HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

37 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd Page 38 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd 31. It was submitted that since the issue has attained finality upto the level of the Tribunal for A.Y.s 2005-06 to 2007-08 and the relief

NCC LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

37 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd Page 38 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd 31. It was submitted that since the issue has attained finality upto the level of the Tribunal for A.Y.s 2005-06 to 2007-08 and the relief

NCC LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(1), HYDERABAD, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

37 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd Page 38 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd 31. It was submitted that since the issue has attained finality upto the level of the Tribunal for A.Y.s 2005-06 to 2007-08 and the relief

NCC LIMITED, ,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(1),, HYDERABAD

Accordingly, we delete the same. Thus, this ground is partly allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

37 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd Page 38 of 65 ITA Nos 73 to 75 and 77 to 80 of 2017 NCC Ltd 31. It was submitted that since the issue has attained finality upto the level of the Tribunal for A.Y.s 2005-06 to 2007-08 and the relief

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

depreciation, ICDS compliance, TDS payments, assets, borrowings, and other supporting documents. The assessee submitted partial and complete responses on various dates and also participated in video- conference proceedings on 12.09.2023, furnishing explanations on ICDS and related issues. Since the assessee had reported large 6 Gainsight Software Private Limited value international transactions in respect of provision of software development services

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

depreciation in respect of such machinery or plant has been allowed or is allowable under the provisions of this Act in computing the total income of any person for any period prior to the date of the installation of machinery or plant by the assessee. Explanation 2.—Where in the case of an undertaking, any machinery or plant

REPAL GREEN POWER PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 8(1), HYDERABAD

In the result, both the appeals of the Assessee are\nallowed

depreciation under Section 32(ia), without revising the\nopening WDV of plant and machinery on account of the amount of\ndepreciation disallowed in the previous year.\nInvestment allowance under Section 32AD\n8. On the facts and circumstances of the case and in law, the Id. AO,\nunder the direction of the Hon'ble DRP, erred in not appreciating\nthat

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NEXT EDUCATION INDIA PRIVATE LIMITED , HYDERABAD

In the result, appeal of the Revenue and cross appeal filed by the assessee are partly allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2016-17

depreciation loss of Rs.13,69,49,466/-. The case was selected for manual scrutiny. Accordingly, notice u/s.143(2) of the Act dt.14-07-2017 was issued and duly served on the assessee-company. Later on, notice u/s.142(1) of the Act dt.03-11-2018, 14-11-2018 and 30-11-2018, 08-12-2018 and 15- 12-2018 were issued in e-proceedings

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

37(1) of the Act. The company can claim deduction for hundred percent of the donation of Rs. 1 crores paid to Prime Minister's National Relief Fund u/s 80G(2)(iiia) read with section 80G(1)(i) of the Act. The company claim deduction to the extent of fifty percent of the donation of Rs. 1 crores paid

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

37, ought not to have disallowed Rs.\n41,08,54,250/- under section 40A(9) of the Income Tax Act, 1961.\nFor this and for such other grounds that may be urged at the time of hearing your appellant\nsubmits that the additions made by the Assessing Officer may be deleted.\nITA No.308/Hyd/2024 (A.Y 2020-21) Revenue\n(i) Whether