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

Disallowance of CSR expenses of Rs. 1,42,97,133/- against the returned income of Rs. 50,81,16,931/-. 2.1 Feeling aggrieved, the assessee raised certain objections before the Ld. DRP. The Ld. DRP, after considering the submissions of the assessee and also going through the material available on record, dismissed the objections raised by the assessee. Thereafter

DCIT., CIRCLE-8(1), HYDERABAD vs. DBS TECHNOLOGY SERVICES INDIA PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Deputy Commissioner Of Vs. M/S. Dbs Technology Income Tax, Services India Private Circle – 8(1), Limited, Hyderabad. Hyderabad. Pan : Aafcd5584N (Appellant) (Respondent) C.O.No.2/Hyd/2023 Assessment Year 2019-20 Dbs Technology Services India Vs. Deputy Commissioner Of Private Limited, Income Tax, Circle – 8(1), Hyderabad. Hyderabad. Pan : Aafcd5584N (Cross Objector / (Appellant/Revenue) Respondent) Assessee By: Sri M. P. Lohia, C.A. Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 11.07.2023 Date Of Pronouncement: 21.07.2023 आदेश / O R D E R Per Laliet Kumar, Jm: The Appeal & Cross-Objection Filed By The Revenue For A.Y. 2019-20 Arise From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi

ii) no loss referred to in sub-section (1) of section 72 or sub- section (1) or sub-section (3) of section 74, in so far as such loss relates to the business of the undertaking, shall be carried forward or set off where such loss relates to any of the relevant assessment years 16[ending before

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)(ii) of the Act. Accordingly, the Assessing Officer disallowed the entire revenue expenditure debited in the P & L A/c and has allowed 25% of depreciation on the said expenditure and balance amount of Rs.106,95,46,203/- has been disallowed and added back to the total income of the appellant company. 15. On appeal, the learned

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

25% applicable to an intangible\nasset. The Assessing Officer had discussed the issue at\nlength in light of definition of non-compete fee and it's\npurpose and also how the said claim is not falls within the\nambit of any other business or commercial right of similar\nnature as defined under section 32(1)(ii

ACIT, CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

25% applicable to an intangible\nasset. The Assessing Officer had discussed the issue at\nlength in light of definition of non-compete fee and it's\npurpose and also how the said claim is not falls within the\nambit of any other business or commercial right of similar\nnature as defined under section 32(1)(ii

ACIT., CIRCLE-5(1), HYDERABAD vs. EENADU TELEVISION PRIVATE LIMITED, HYDERABAD

25% applicable to an intangible\nasset. The Assessing Officer had discussed the issue at\nlength in light of definition of non-compete fee and it's\npurpose and also how the said claim is not falls within the\nambit of any other business or commercial right of similar\nnature as defined under section 32(1)(ii

EENADU TELEVISION PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

25% applicable to an intangible\nasset. The Assessing Officer had discussed the issue at\nlength in light of definition of non-compete fee and it's\npurpose and also how the said claim is not falls within the\nambit of any other business or commercial right of similar\nnature as defined under section 32(1)(ii

BSCPL AURANG TOLLWAY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay, wherein it was submitted that the appeal for the relevant assessment year was required to be filed within 60 days from the date of receipt of the order passed under Section 263 of the Income-tax Act, 1961. However, the

10 BSCPL Aurang Tollway Limited the Revenue, and thus, set aside the assessment order passed by the A.O. and directed the A.O. to pass suitable order disallowing the excess claim of depreciation, which resulted on account of allowing depreciation instead of amortisation amounting to Rs. 18,104.27 lakhs and reduce the resultant loss to be carried forward to the subsequent

CHINTALAPATI HOLDINGS PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD

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

ii) of the Rules has to be quantified in the proportion average investment in share capital bears to the average total assets. It is further stated that the learned CIT(A) failed to consider that the expenditure disallowable under section 14A of the Act read with rule 8D of the Rules, shall not exceed the interest expenditure debited

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

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

ii) of the Rules has to be quantified in the proportion average investment in share capital bears to the average total assets. It is further stated that the learned CIT(A) failed to consider that the expenditure disallowable under section 14A of the Act read with rule 8D of the Rules, shall not exceed the interest expenditure debited

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

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

ii) of the Rules has to be quantified in the proportion average investment in share capital bears to the average total assets. It is further stated that the learned CIT(A) failed to consider that the expenditure disallowable under section 14A of the Act read with rule 8D of the Rules, shall not exceed the interest expenditure debited

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

25. MS. M. Narmada, learned CIT-DR for the Revenue, on the other hand, submitted that, the interest paid or payable on ECBs should be of all costs which includes other charges also. Although, the appellant company claims to have paid interest which is at par with RBI circular rate, but, there is no clarity as to whether

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED, HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

10 of the order of the Ld.CIT(A). The sum and substance of the argument of the assessee before the Ld.CIT(A) are that the payment of bonus to two directors is in terms of contractual agreement for services rendered to the company and the said payment does not fall under the purview of any sum paid to an employee

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED , HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

10 of the order of the Ld.CIT(A). The sum and substance of the argument of the assessee before the Ld.CIT(A) are that the payment of bonus to two directors is in terms of contractual agreement for services rendered to the company and the said payment does not fall under the purview of any sum paid to an employee

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

10. A settlement\nwithin the meaning of sub-section (3) of Section 18 of the\nIndustrial Disputes Act is binding on both the parties and\ncontinues to remain in force unless the same is altered,\nmodified or substituted by another settlement......\".\n12. A similar issue came up for consideration before the\nJharkhand High Court at Ranchi in L.P.A.No

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

In the result, assessee's appeals for the A

10. A settlement\nwithin the meaning of sub-section (3) of Section 18 of the\nIndustrial Disputes Act is binding on both the parties and\ncontinues to remain in force unless the same is altered,\nmodified or substituted by another settlement......\".\n12. A similar issue came up for consideration before the\nJharkhand High Court at Ranchi in L.P.A.No

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

ii) provision for CPRMSE – NCWA employees of Rs.54,13,04,000/-, the ground no. 8 of the ITA Nos.285 & 307/Hyd/2024 18 assessee relates to the disallowance of Rs.1,49,588/- on account of non-deduction of TDS, the ground no.9 of the assessee relates to the disallowance of Rs.5,73,480/- under section

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

ii) provision for CPRMSE – NCWA employees of Rs.54,13,04,000/-, the ground no. 8 of the ITA Nos.285 & 307/Hyd/2024 18 assessee relates to the disallowance of Rs.1,49,588/- on account of non-deduction of TDS, the ground no.9 of the assessee relates to the disallowance of Rs.5,73,480/- under section

ASIAN INSTITUTE OF GASTROENTEROLOGY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeals filed by the assessee for\nboth the

25,63,360/-. The case has been\nsubsequently taken-up for revision proceedings and\naccordingly, a show cause notice u/sec.263 of the Act dated\n18.02.2025 was issued to the assessee and called-upon the\nassessee to explain as to why the assessment order passed\nby the Assessing Officer shall not be revised for the reasons\nstated in the said show