ACIT., EXEMPTIONS CIRCLE-1(1), HYDERABAD vs. PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025

Section 11(1)(a) of the Act. Therefore in the present case, the disallowance of Rs. 10,15,818/- which

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

11. We have given thoughtful consideration to the subject issue, and concur with the Ld. AR that it is now well settled by a catena of judicial pronouncements, that as per law, as was available on the statute during the year under consideration, no disallowance under section

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

disallowance under Rule 8D of the Rules should be confined to the investments which have actually yielded exempt income during the year. The relevant portion of the order of the Tribunal contained at para no. 11 is reproduced as under :\n\"11. We have considered the submissions of both the parties and have perused the record of the case

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

11-2-2014\nSECTION 14A OF THE INCOME-TAX ACT, 1961, READ WITH RULE 8D OF\nTHE INCOME-TAX RULES, 1962 - EXPENDITURE INCURRED IN RELATION\nTO INCOME NOT INCLUDIBLE IN TOTAL INCOME - CLARIFICATION ON\nDISALLOWANCE OF EXPENSES UNDER SECTION 14A IN CASES WHERE\nCORRESPONDING EXEMPT INCOME HAS NOT BEEN EARNED DURING\nTHE FINANCIAL YEAR\nSection 14A of the Income

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

11. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). 12. Before the Ld. CIT(A), the assessee has challenged the addition made by the A.O. towards disallowance of expenditure under section

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

11. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). 12. Before the Ld. CIT(A), the assessee has challenged the addition made by the A.O. towards disallowance of expenditure under section

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

11. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). 12. Before the Ld. CIT(A), the assessee has challenged the addition made by the A.O. towards disallowance of expenditure under section

PRATHIMA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT (EXEMPTIONS) CIRCLE-1(1), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

disallowing of depreciation of Rs.7,95,37,619 on assets that were acquired prior to previous year relevant to AY 2015-16 during which the section is not in vogue and is not applicable. 3. The Hon. CIT-A ought to have appreciated that the amendment brought into section 11

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

11,36,087/- under the normal\nprovisions and “book profit” under section 115JB at Rs. 231,31,26,864/-\nafter making certain additions/disallowances, viz. (i). disallowance

PRASAD FILM LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-6(1), HYDERABAD

In the result appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

disallowance under section 14A of the Act. The assessee has referred to certain judicial precedents in support of it’s arguments including the decision of Hon’ble Bombay High Court in the case of Tata 11

FEDERATION OF AP COOPERATIVE URBAN BANKS AND CREDIT SOCIETIES LIMITED HYD,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.464/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Federation Of Ap Vs. Income Tax Officer Cooperative Urban Banks Ward 9(1) & Credit Societies Ltd. Hyderabad Hyd, Hyderabad Pan:Aaaaf7350F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri V. Ravish Bhatt, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 29/10/2025 घोषणा की तारीख/Pronouncement: 07/11/2025

disallowance of deduction under Section 80P of the Act cannot be made through adjustment under Section 143(1). Finally, the Ld. AR prayed before the Bench to delete the addition of Rs.36,70,431/-. Page 6 of 11

JASPER INDUSTRIES PVT LTD,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

disallowance made under Section 14A r.w.r. Rule 8D be restricted to Rs. 23,000/-, being the exempt dividend income earned by the assessee during the year under consideration, and all other grounds may be treated as not pressed. 11

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

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

disallowance under section 14A of the Act read with rule 8D of the Income Tax Rules, 1962 (‘the Rules’). This action of the learned CIT(A) is challenged by the assessee under grounds 3 to 11

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

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

disallowance under section 14A of the Act read with rule 8D of the Income Tax Rules, 1962 (‘the Rules’). This action of the learned CIT(A) is challenged by the assessee under grounds 3 to 11

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

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

disallowance under section 14A of the Act read with rule 8D of the Income Tax Rules, 1962 (‘the Rules’). This action of the learned CIT(A) is challenged by the assessee under grounds 3 to 11

KRANTHI EDUCATIONAL SOCIETY,BHADRACHALLAM vs. DCIT., EXEMPTION CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of our observations given hereinabove

Bench: the Ld. CIT(A).

disallowance of Rs.10,72,66,472/- and dismissed the appeal. 6. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before us. 7. The learned counsel for the assessee Shri DLS Narasimha Rao, CA, submitted that, the denial of exemption under Section 11

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business and further, the assessee has paid interest on customers' advance

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business and further, the assessee has paid interest on customers' advance

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business and further, the assessee has paid interest on customers' advance