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. 22 9. The Ld. Counsel for the assessee submitted that, the disallowance of Rs. 10,15,818/- sustained by CIT(A), will result in addition of the amount twice to the gross total income of the assessee, once through foreign contribution received reimbursed amount is already included in the total income

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 of the Act by way of insertion

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

11,500/-; (ii). disallowance of the claim of the assessee company for deduction under section 80G in respect of donations forming part of CSR expenditure, holding that CSR expenditure being mandatory in nature could not qualify for deduction under section 80G except in cases specifically provided: Rs. 1,85,88,450/-; (iii). an estimated disallowance of 1% of the total

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

6. In the backdrop of these facts the Tribunal's order was upheld by the Hon'ble High Court and Hon'ble Supreme Court. The Hon'ble Supreme Court, inter alia, held that it is the purpose of the expenditure that is relevant in determining the applicability of section 57(iii) and that purpose must be making or earning

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

6. In the backdrop of these facts the Tribunal's order was upheld by the\nHon'ble High Court and Hon'ble Supreme Court. The Hon'ble Supreme Court,\ninter alia, held that it is the purpose of the expenditure that is relevant in\ndetermining the applicability of Section 57(iii) and that purpose must be making\nor earning

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)

Section 40(a)(ia) of the Act. 20. To sum up, out of the disallowance of Rs. 13,02,340/-, the assessee gets relief of Rs. 45,086/-, and the balance addition of Rs. 12,57,454/- is upheld. 21. In the result, the appeal of assessee in ITA No.280/Hyd/2025 is partly allowed. ITA No.281/Hyd/2025

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)

Section 40(a)(ia) of the Act. 20. To sum up, out of the disallowance of Rs. 13,02,340/-, the assessee gets relief of Rs. 45,086/-, and the balance addition of Rs. 12,57,454/- is upheld. 21. In the result, the appeal of assessee in ITA No.280/Hyd/2025 is partly allowed. ITA No.281/Hyd/2025

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)

Section 40(a)(ia) of the Act. 20. To sum up, out of the disallowance of Rs. 13,02,340/-, the assessee gets relief of Rs. 45,086/-, and the balance addition of Rs. 12,57,454/- is upheld. 21. In the result, the appeal of assessee in ITA No.280/Hyd/2025 is partly allowed. ITA No.281/Hyd/2025

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

11,500/-; (ii). disallowance of the claim of the assessee company\nfor deduction under section 80G in respect of donations forming part of\nCSR expenditure, holding that CSR expenditure being mandatory in\nnature could not qualify for deduction under section 80G except in\ncases specifically provided: Rs. 1,85,88,450/-; (iii). an estimated\ndisallowance of 1% of the total

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

6 ITA.No.113/Hyd./2025 or resources. Although, the assessee has not incurred any expenditure, but, has made disallowance of Rs.5,000/- considering the provisions of section 14A of the Act. The learned CIT(A) after considering the relevant submissions of the assessee and also taken note of certain judicial precedents held that, non-maintenance of separate books of accounts

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

SHELADIA ASSOCIATES INC,SD ROAD vs. ADIT(INT TAXN)-2, HYDERABAD

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No. 537/Hyd/2023 (धििाारण वर्ा / Assessment Year: 2021-22) Sheladia Associates Inc, Adit (Int Taxn)-2, Secunderabad Vs. Hyderabad [Pan No. Aafcs7792F] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

section 133(6) of the Act during assessment proceedings vitiated the remand report. 11. In these circumstances, we are of the considered opinion that disallowing

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

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 of this appeal. 15. Apart from this, learned CIT(A) also considered the addition on account of long term capital loss. She agreed with

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 of this appeal. 15. Apart from this, learned CIT(A) also considered the addition on account of long term capital loss. She agreed with

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 of this appeal. 15. Apart from this, learned CIT(A) also considered the addition on account of long term capital loss. She agreed with

ROLON SEALS INTERNATIONAL,HYDERABAD vs. ITO., WARD-11(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.947/Hyd/2025 Assessment Year 2023-2024 Rolon Seals International, The Income Tax Officer, Hyderabad – 500 063. Vs. Ward-11(1), Telangana. Hyderabad. Pan Aarfr2216G (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Sashank Dundu, Advocate राज" व "ारा /Revenue By: G Saratha, Sr. Ar

6) of section 10A/10B of the 1.T. Act and confirmed the disallowance without noticing these sub- sections do not mandate that the return of income should be filed within the specified due date u/s 139(1) of the 1L.T. Act in order to be entitled to the said deduction u/s 10AA of the LT. Act. 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)

6 Jasper Industries Pvt. Ltd further submitted that the investments made in equity instruments were out of its own funds and for business purposes and that no specific expenditure was incurred for earning the dividend income. Therefore, the A.O. is erred in invoking the provisions of Section 14A read with Rule 8D and making disallowance

KAUSALYA AGRO FARMS AMD DEVELOPERS PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes, in terms of our above findings

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

6 purpose of verification of the disallowance made by the Ld. AO under section 36(1)(iii) of the Act. In this regard, the Ld. AR invited our attention to para no.3 of page no.2 of the assessment order, wherein the Ld. AO has himself recorded that the assessee had filed a reply dated 12.01.2022, enclosing books of account, computation