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, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49,12

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, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49,12

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, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49,12

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

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

section 24(b) of the Act has to be disallowed. 12. Learned CIT(A) found that the assessee earned Rs. 16,67,49,213/- towards

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

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

section 24(b) of the Act has to be disallowed. 12. Learned CIT(A) found that the assessee earned Rs. 16,67,49,213/- towards

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

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

section 24(b) of the Act has to be disallowed. 12. Learned CIT(A) found that the assessee earned Rs. 16,67,49,213/- towards

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)

12. We have heard both the parties, perused the material available on record and gone through the orders of the authorities below. The only issue involved in the present appeal is with regard to the disallowance made under Section

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

12 of Paper Book no. 1. Accordingly, the Ld. AR submitted that the interest-free funds available with the assessee were more than sufficient to cover the impugned investments. Therefore, there should not be any disallowance under section

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

12% of Rs.4,57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges

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

12% of Rs.4,57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges

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

12% of Rs.4,57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges

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

12% of Rs.4,57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges

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

12% of Rs.4,57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges

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

disallowance made by the Ld. AO under section 40A(9) of the Act is not sustainable. Accordingly, the addition of Rs.38,15,00,000/- made by the Ld. AO is directed to be deleted. Ground nos. 3 to 6 of the assessee’s appeal are allowed. 12

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

disallowance made by the Ld. AO under section 40A(9) of the Act is not sustainable. Accordingly, the addition of Rs.38,15,00,000/- made by the Ld. AO is directed to be deleted. Ground nos. 3 to 6 of the assessee’s appeal are allowed. 12

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

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

12,350/- and sustained the balance addition of Rs. 4,60,131/-. However, the learned CIT(A) sustained additions made by the A.O. towards disallowance of interest on TDS, disallowance of EPF & ESI and disallowance of interest under Section

NIPPON KOEI CO. LTD.,BEGUMPET vs. ADIT (INTERNATIONAL TAXATION)- 2, HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

disallowance made by the Ld. AO under section 40(a)(i) of the Act may be deleted. 12. We have

INCOME TAX OFFICER, WARD-1(3), HYDERABAD vs. BHAGYANAGAR INDIA LIMITED , SECUNDERABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1200/Hyd/2019 (निर्धारण वर्ा/Assessment Year:2016-17) Income Tax Officer, M/S. Bhagyanagar India Ward-1(3), Hyderabad. Vs. Limited, Hyderabad. Pan:Aaacb8963C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.C. Devdas, C.A. रधजस् व द्वधरध/Revenue By: Shri Narender Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 24/07/2025 घोर्णध की तधरीख/Pronouncement: 08/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Hyderabad (“Ld. Cit(A)”), Dated 16.05.2019 For The A.Y. 2016-17. 2. The Revenue Has Raised The Following Grounds Of Appeal:

disallowance under section 14A raised by the assessee are allowed. 8.1. In view of the above, assessee appeal in ITA.No.99/Hyd/2012 is partly allowed.” 12