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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

section 43(6) of Act. Hence, the VITP Pvt. Ltd. claimed excess WDV of Rs.56,78,75,869/-. This excess WDV resulted in excess claim of depreciation of Rs.3,37,71,787/- in AY 2017- 18 with a tax effect of Rs.1,76,48

MANJU DUDALA,HYDERABAD. vs. INCOME TAX OFFICER, WARD-11(3), HYDERABAD.

In the result, appeal ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 32(1)(U) of the Act?. 3. Whether, on the facts and in the circumstances of the case and in law, the CIT(A) was right and justified in following the directions of the ITAT in allowing the claim of cost of production of TV serials and programmes as revenue expenditure as against depreciation granted by AO treating

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

section 14A read with Rule 8D of I.T. Rules, 1962. 22. The assessee has claimed an amount of Rs.1,98,96,436/- as exempt income on account of dividend income received on investments in units of mutual funds. The assessee has made a suo motu disallowance of 43 ITA.No.111/Hyd./2022 expenditure relatable to exempt income of Rs.11

ITO, WARD-16(2), HYDERABAD, HYDERABAD vs. PADMA VAMSI TEXTILE MARKET PVT. LTD., HYDERABAD, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2007-08 Income-Tax Officer, Vs. Padma Vamsi Textile Market Ward – 16(2), Hyderabad. Pvt. Ltd., Hyderabad. Pan – Aadcp 3957F (Appellant) (Respondent) Revenue By : Smt. Komali Krishna Assessee By : Shri B. Satyanarayana Murthy Date Of Hearing : 23-04-2019 Date Of Pronouncement : 03-05-2019

section 50C applies to depreciable assets also and agreed with the submissions of the ld. DR. Further, he submitted that no doubt, AO adopted fair market value of the property at Rs. 1,05,51,320/- and he brought to our notice, WDV value of the assets, which is Rs. 1,02,01,998/- as on 31/03/2007. He submitted that

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 251(1) of the Act. 2. The ld.CIT(A) erred in treating the cost of production of TV serials and programmes as revenue expenditure. 3. The ld.CIT(A) erred in allowing depreciation @ 25% on ‘Film Software Library’ instead of 15% allowable on ‘Plant and Machinery’.” 2. The brief facts of the case are that assessee is a company engaged

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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

In the result, the appeal of the assessee in ITA

Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)

48,03,873/- under section 115JB of the Act. The case of the assessee was selected for scrutiny, and the assessment order under section 143(3) r.w.s. 144C(3) and 144B was passed by the Learned Assessing Officer (“Ld. AO”) on 28.06.2021, making an addition of Rs.2,26,82,071/- on account of transfer pricing adjustment. 4. Thereafter

PENNAR INDUSTRIES LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1),, HYDERABAD

In the result, the appeal filed by the assessee company is partly allowed/partly allowed for statistical purposes

Bench: Us:

Section 115QA was not paid on buy-back of shares amounting to Rs. 20,48,00,000/-, the Ld. AR rebutted the same and stated that the said observation was factually incorrect. The Ld. AR had drawn our attention to the details of the buy back of shares by the assessee company from the shareholders on the basis

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. MYLAN LABORATORIES LIMITED , HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

depreciation on goodwill not be treated as wrong claim that should be disallowed; , and (iii) how extending liabilities were shown in the financials or books of account. The assessee filed its detailed reply. However, ld. CIT(A) was not convinced and he held that deal value of the shares was INR 5,978 crores while the corresponding investment recorded

MYLAN LABORATORIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

depreciation on goodwill not be treated as wrong claim that should be disallowed; , and (iii) how extending liabilities were shown in the financials or books of account. The assessee filed its detailed reply. However, ld. CIT(A) was not convinced and he held that deal value of the shares was INR 5,978 crores while the corresponding investment recorded

TELANGANA STATE POWER GENERATION CORPORATION LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2016-17 Telangana State Power Vs. Asst. Commissioner Of Generation Corporation Income-Tax, Ltd., Hyderabad. Circle – 2(2), Hyderabad. Pan – Aafct 0257Q (Appellant) (Respondent) Assessee By: Shri M. Chandramouleswara Rao Revenue By: Shri Yvst Sai Cit Dr Date Of Hearing: 17/03/2021 Date Of Pronouncement: 14 /06/2021 O R D E R Per L.P. Sahu, Am: This Appeal Filed By The Assessee For Ay 2016-17 Is Directed Against The Cit(A) - 2, Hyderabad’S Order, Dated 21/08/2019 Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961 ; In Short “The Act”.

48,852/- under normal provisions and Rs. 400,86,84,369/ -under MAT provisions. The A.O disallowed investment allowance U/s 32AC of Rs. 319,08,63,958/-, disallowed other income for 80lA of Rs. 3,77,42,894/- and made disallowance u/s 14A of Rs. 9,40,42,000/ -. 3. The subject matter of appeal is only regarding disallowance

OCEAN SPARKLE LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-16(3), HYDERABAD, HYDERABAD

In the result, both the appeals for AY 2011-12 and 2012-

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

depreciation has been allowed under this Act or 9 I.T.A. Nos. 438 to 440/Hyd/2016 Ocean Sparkle Ltd., Hyd. under the Indian Income- tax Act, 1922 (11 of 1922 ), the provisions of sections 48

OCEAN SPARKLE LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-16(3), HYDERABAD, HYDERABAD

In the result, both the appeals for AY 2011-12 and 2012-

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

depreciation has been allowed under this Act or 9 I.T.A. Nos. 438 to 440/Hyd/2016 Ocean Sparkle Ltd., Hyd. under the Indian Income- tax Act, 1922 (11 of 1922 ), the provisions of sections 48

OCEAN SPARKLE LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-16(3), HYDERABAD, HYDERABAD

In the result, both the appeals for AY 2011-12 and 2012-

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

depreciation has been allowed under this Act or 9 I.T.A. Nos. 438 to 440/Hyd/2016 Ocean Sparkle Ltd., Hyd. under the Indian Income- tax Act, 1922 (11 of 1922 ), the provisions of sections 48

PATNA BAKHTIYARPUR TOLLWAY LIMITED,HYDERABAD vs. ACIT., CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleassessment Year – 2017-18 Patna Bakhtiyarpur Tollway Vs. Acit Circle-16(2) Limited Hyderabad Hyderabad Pan : Aafcp9577K (Appellant) (Respondent) Assessee By: Shri S.Rama Rao, Ar Revenue By: Ms.K.Haritha, Cit-Dr Date Of Hearing: 05.12.2024 31.12.2024 Date Of Pronouncement:

depreciation on the intangible asset amounting to Rs.162,48,67,242/-and has only restricted to the amortization of Rs.58,16,55,020/-. Relevant paragraphs of the order of the learned Assessing Officer are available at para 3 at page 4,5 and 6. The Ld.AR has submitted that the Ld.CIT(A) had examined this issue at page

FUSION LASTEK TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

Bench: Us:

Section. 48. The income chargeable under the head "Capital gains" shall be computed, by deducting from the full value of the consideration received or accruing as a result of the transfer of the capital asset the following amounts, namely:— (i) expenditure incurred wholly and exclusively in connection with such transfer; (ii) the cost of acquisition of the asset