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

disallowance of\nRs.3,34,45,018/- under Section 14A of the Act read with Rule 8D of the Income-\ntax Rules, 1962 (“the Rules") to the income computed by the CPC under\nsection 143(1) at Rs.223,89,67,030/-, and assessed the total income of the\nassessee at Rs.227,24,12

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 read with Rule 8D of I.T. Rules, 1962, the Assessing Officer shall arrive at a satisfaction that, the claim of the assessee that, no 12

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

disallowing deduction under Section 80P of the Act. In this regard, we have gone through the relevant portion of the order of the Ld. First Appellate Authority placed at page no.7 and 8 of the appellate order, which is to the following effect: 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

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

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

12 taxmann.com 499\n(Chennai). Hence the disallowance of deduction under section 80-IA\nin respect of the sale of scrap

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

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