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

48,03,873/-\nunder section 115JB of the Act. The case of the assessee was\nselected for scrutiny, and the assessment order under section\n143(3) r.w.s. 144C(3) and 144B was passed by the Learned\nAssessing Officer (“Ld. AO”) on 28.06.2021, making an addition of\nRs.2,26,82,071/- on account of transfer pricing adjustment.\n4.\nThereafter

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

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

section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest, income-tax was deductible at the\nrates in force during that financial year with effect from 1-4-\n1975, if the amount exceeded Rs.1,000.\nPursuant to those instructions, the Land Acquisition\nOfficers, while depositing the enhanced compensation

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

In the result, assessee's appeals for the A

section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest, income-tax was deductible at the\nrates in force during that financial year with effect from 1-4-\n1975, if the amount exceeded Rs.1,000.\nPursuant to those instructions, the Land Acquisition\nOfficers, while depositing the enhanced compensation

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

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

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

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

ALTIUX INNOVATIONS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1006 To 1008/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Altiux Innovations (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 1(1) Pan: Aalca9069R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sai Sarikonda, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Pronouncement: 16/01/2025 आदेश/Order

depreciation of an amount being Rs. 8,52,48,886/ -, allowable under section 32 of the Act, under the facts

ALTIUX INNOVATIONS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1 (1), HYDERABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1006 To 1008/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Altiux Innovations (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 1(1) Pan: Aalca9069R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sai Sarikonda, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Pronouncement: 16/01/2025 आदेश/Order

depreciation of an amount being Rs. 8,52,48,886/ -, allowable under section 32 of the Act, under the facts

ALTIUX INNOVATIONS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1006 To 1008/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Altiux Innovations (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 1(1) Pan: Aalca9069R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sai Sarikonda, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Pronouncement: 16/01/2025 आदेश/Order

depreciation of an amount being Rs. 8,52,48,886/ -, allowable under section 32 of the Act, under the facts

NETMATRIX CROP CARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

Bench: Us:

48; (ii) fair market value of the capital assets as on the date of transfer, calculated in the prescribed manner, shall be deemed to be the full value of the consideration received or accruing as a result of the transfer of such capital asset. (3) Every assessee, in the case of slump sale, shall furnish in the prescribed form

DR. REDDY`S BIOSCIENCES LIMITED,HYDERABAD vs. ACIT, CIRCLE-17(1), HYDERABAD

In the result, appeal of assessee is allowed in part

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

depreciation cannot be sustained. Accordingly, we direct the deletion of the same. 11. Coming to the second addition on account of the cost of acquisition, learned Assessing Officer found that during the year, the assessee sold only 40% of the land while claiming the cost of acquisition in respect of the balance land also. Assessment order reads that the assessee