RATNA INFRASTRUCTURE PROJECTS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

section 40A(3) of the IT Act. 5. The company has executed works awarded by various departments and works taken on sub-contracts executed by the company directly by the men and machinery of the company and partly through sub-contractors. In addition to that the company has also under taken works on back to back basis wherein the work

RATNA INFRASTRUCTURE PROJECTS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

section 40A(3) of the IT Act. 5. The company has executed works awarded by various departments and works taken on sub-contracts executed by the company directly by the men and machinery of the company and partly through sub-contractors. In addition to that the company has also under taken works on back to back basis wherein the work

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:

40A(9) of the I.T. Act, 1961 as this payment is not made for the expenses provided u/s 36(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered

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:

40A(9) of the I.T. Act, 1961 as this payment is not made for the expenses provided u/s 36(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered

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:

40A(9) of the I.T. Act, 1961 as this payment is not made for the expenses provided u/s 36(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered

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:

40A(9) of the I.T. Act, 1961 as this payment is not made for the expenses provided u/s 36(1)(iv) &(iv) of the Act. The relevant finding in para 9.2 are as under: 7. The learned CIT (A) has confirmed the order of the Assessing Officer. At the outset, we note that this issue has been now considered

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.

40a(ia) can be made. The assessee's additional ground of appeal No.10 is accordingly treated as allowed for statistical purposes”. 4.1 Respectfully following the same, this ground of appeal of the assessee is also remitted to the file of the A.O with similar directions and the grounds are treated as allowed for statistical purposes and revenue’s appeal

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.

40a(ia) can be made. The assessee's additional ground of appeal No.10 is accordingly treated as allowed for statistical purposes”. 4.1 Respectfully following the same, this ground of appeal of the assessee is also remitted to the file of the A.O with similar directions and the grounds are treated as allowed for statistical purposes and revenue’s appeal

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. VIGNANA JYOTHI, HYDERABAD

In the result, the appeals of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation as his decision is in consonance with the decision of ITAT cited supra and dismiss the grounds raised by the revenue in AY 2005-06 in ITA No. 2210/Hyd/2017 as ground No. 6 and in AY 2006-07 in ITA No. 2211/Hyd/2017 as ground No. 6. 11.1 Since, similar issue raised

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. VIGNANA JYOTHI, HYDERABAD

In the result, the appeals of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation as his decision is in consonance with the decision of ITAT cited supra and dismiss the grounds raised by the revenue in AY 2005-06 in ITA No. 2210/Hyd/2017 as ground No. 6 and in AY 2006-07 in ITA No. 2211/Hyd/2017 as ground No. 6. 11.1 Since, similar issue raised

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. VIGNANA JYOTHI, HYDERABAD

In the result, the appeals of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation as his decision is in consonance with the decision of ITAT cited supra and dismiss the grounds raised by the revenue in AY 2005-06 in ITA No. 2210/Hyd/2017 as ground No. 6 and in AY 2006-07 in ITA No. 2211/Hyd/2017 as ground No. 6. 11.1 Since, similar issue raised

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. VIGNANA JYOTHI, HYDERABAD

In the result, the appeals of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation as his decision is in consonance with the decision of ITAT cited supra and dismiss the grounds raised by the revenue in AY 2005-06 in ITA No. 2210/Hyd/2017 as ground No. 6 and in AY 2006-07 in ITA No. 2211/Hyd/2017 as ground No. 6. 11.1 Since, similar issue raised

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. VIGNANA JYOTHI, HYDERABAD

In the result, the appeals of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation as his decision is in consonance with the decision of ITAT cited supra and dismiss the grounds raised by the revenue in AY 2005-06 in ITA No. 2210/Hyd/2017 as ground No. 6 and in AY 2006-07 in ITA No. 2211/Hyd/2017 as ground No. 6. 11.1 Since, similar issue raised

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. VIGNANA JYOTHI , HYDERABAD

In the result, the appeals of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation as his decision is in consonance with the decision of ITAT cited supra and dismiss the grounds raised by the revenue in AY 2005-06 in ITA No. 2210/Hyd/2017 as ground No. 6 and in AY 2006-07 in ITA No. 2211/Hyd/2017 as ground No. 6. 11.1 Since, similar issue raised

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. VIGNANA JYOTHI, HYDERABAD

In the result, the appeals of the revenue in ITA No

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

depreciation as his decision is in consonance with the decision of ITAT cited supra and dismiss the grounds raised by the revenue in AY 2005-06 in ITA No. 2210/Hyd/2017 as ground No. 6 and in AY 2006-07 in ITA No. 2211/Hyd/2017 as ground No. 6. 11.1 Since, similar issue raised

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

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

40A(3) of the Act and the ground no. 10 of the assessee relates to the disallowance of Rs.11,67,82,251/- on account of assets written off. In this regard, the Ld. AR submitted that all the aforesaid amounts were duly reported by the auditor in the tax audit report under the respective reporting clauses. However, while filing

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

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

40A(3) of the Act and the ground no. 10 of the assessee relates to the disallowance of Rs.11,67,82,251/- on account of assets written off. In this regard, the Ld. AR submitted that all the aforesaid amounts were duly reported by the auditor in the tax audit report under the respective reporting clauses. However, while filing

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.283, 284 & 286/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F Vs. Acit, Circle - 1 Khammam & Acit, Circle 13(1) Hyderabad & आ.अपी.सं / Ita Nos.300, 301 & 308/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. Cit, Circle 13(1) Hyderabad (Appellant) Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / 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:

40A(9) of the Income Tax Act, 1961. 5. Your Appellant submits that the CIT(A) as well as the Assessing Officer disallowed investment allowance under section 32AC of Rs.240,00,69,986/- on assumption that electricity is not an article or thing and also ignored the bills and certificates in support of acquisition and installation, on assumption, which