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

depreciation on ‘goodwill’ accounted on account of amalgamation. The Assessing Officer and DRP after considering the relevant facts, has rightly rejected the claim of the assessee. Thus, we are inclined to uphold the Directions of the DRP / Order of Assessing Officer and reject the grounds raised by the assessee on this issue. 21. The next issue that came

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

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 32(1)(ii) of the Act preceding the term "business or commercial rights of similar nature" it is seen that intangible assets are not of the same kind and are clearly distinct from one another. The legislature thus did not intend to provide for depreciation only in respect of the specified intangible assets but also to other categories

VERMEIREN INDIA REHAB PRIVATE LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

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

Bench: Shri Manjunatha G & Shri Ravish Sood

97,208. Ground No. 2: Corporate Tax: Denial of Depreciation 2.1. In law and facts and circumstances of the case, the Ld. AO/DRP have erred in denying the depreciation claimed by the Assessee on the following grounds: 2.1.1. That the Ld. AO/DRP erred in not granting depreciation on building under section

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

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 45Q,an overriding effect is given to the directions vis-a-vis 'income recognition' principles in the Companies Act. These directions constitute a code by themselves. However, these directions and the Income-tax Act operate indifferent areas. These directions have nothing to do with the computation of taxable income', These directions cannot overrule the 'permissible deductions' or 'their exclusion

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVAT LIMITED, HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 45Q,an overriding effect is given to the directions vis-a-vis 'income recognition' principles in the Companies Act. These directions constitute a code by themselves. However, these directions and the Income-tax Act operate indifferent areas. These directions have nothing to do with the computation of taxable income', These directions cannot overrule the 'permissible deductions' or 'their exclusion

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED , HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 45Q,an overriding effect is given to the directions vis-a-vis 'income recognition' principles in the Companies Act. These directions constitute a code by themselves. However, these directions and the Income-tax Act operate indifferent areas. These directions have nothing to do with the computation of taxable income', These directions cannot overrule the 'permissible deductions' or 'their exclusion

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED , HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 45Q,an overriding effect is given to the directions vis-a-vis 'income recognition' principles in the Companies Act. These directions constitute a code by themselves. However, these directions and the Income-tax Act operate indifferent areas. These directions have nothing to do with the computation of taxable income', These directions cannot overrule the 'permissible deductions' or 'their exclusion

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GURUVAYOOR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, appeal of the revenue is partly allowed for statistical purposes in above terms

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 45Q,an overriding effect is given to the directions vis-a-vis 'income recognition' principles in the Companies Act. These directions constitute a code by themselves. However, these directions and the Income-tax Act operate indifferent areas. These directions have nothing to do with the computation of taxable income', These directions cannot overrule the 'permissible deductions' or 'their exclusion

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 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

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

VK WAREHOUSING ENTERPRISES,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

97,973/-. Subsequently, the return of income was selected for scrutiny assessment under CASS and notice under Section 143(2) was issued and duly served upon the assessee firm. As there was no compliance to the statutory notices issued under Sections 143(2) and 142(1), despite repeated opportunities, the AO completed the assessment to the best of his judgment

ACIT., CIRCLE-5(1), HYDERABAD vs. MYLAN LABORATORIES LIMITED, HYDERABAD

In the result. appeal of the Assessee is partly allowed for statistical purposes and appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

97,64,708/-, disallowance of depreciation claimed on goodwill arising out of amalgamation at Rs.1371,56,42,098/-, disallowance of depreciation of non-compete fee of Rs.2,22,932/- and disallowance of expenditure claimed on weighted deduction under section

SIGNODE INDIA LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

97,208. Ground No. 2: Corporate Tax: Denial of Depreciation 2.1. In law and facts and circumstances of the case, the Ld. AO/DRP have erred in denying the depreciation claimed by the Assessee on the following grounds: 2.1.1. That the Ld. AO/DRP erred in not granting depreciation on building under section

SIGNODE INDIA LIMITED,HYDERABAD vs. ACIT, CIRCLE-3(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

97,208. Ground No. 2: Corporate Tax: Denial of Depreciation 2.1. In law and facts and circumstances of the case, the Ld. AO/DRP have erred in denying the depreciation claimed by the Assessee on the following grounds: 2.1.1. That the Ld. AO/DRP erred in not granting depreciation on building under section

ACIT., CIRCLE-6(1), HYDERABAD vs. VK WAREHOUSING ENTERPRISES, HYDERABAD

In the result, both the appeals filed by the assessee firm and\nthe revenue are partly allowed for statistical purposes, in terms of\nour observations recorded hereinabove

97,973/-. Subsequently, the return\nof income was selected for scrutiny assessment under CASS and\nnotice under Section 143(2) was issued and duly served upon the\nassessee firm. As there was no compliance to the statutory\nnotices issued under Sections 143(2) and 142(1), despite\nrepeated opportunities, the AO completed the assessment to the\nbest of his judgment