ACIT, CENTRAL CIRCLE-3(1), HYDERABAD vs. SRI CHAITANYA EDUCATIONAL COMMITTE, VIJAYAWADA

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Section 13(1)(c) r.w.s. 13(2)(c) and 13(2)(g) of the 1.T. Act. The AO has noted that he is not convinced with the reasons for handing over coaching centers to JV and VEMPL. The AO further noted that the appellant has incurred a loss during the immediately preceding year and also during the present year

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

13), Section 80-IA(7) of the Act and Rule 18BB (1) of the Rules. 8. On the facts and circumstances of the case, and in law, the Ld. TPO erred in not following a consistent approach for SDT's on a year-on-year basis. 9. On the facts and circumstances of the case

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

13) of the Act is not correct either in law or on facts and in both. 2. That the facts and in the circumstances of the case and in law, the Ld. DRP is not justified in confirming the specified domestic transfer pricing adjustments made by the lower authorities, totalling Rs. 154,38,00,527/- U/s. 92CA

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

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

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

disallowance under Section 40(a)(ia), and addition towards Form 26AS mismatch. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Shri Sriram Seshadri, C.A., referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.12.2024, submitted

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

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

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowance of donations under Section 80G towards CSR expenditure. 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Ms. Tanmayee Rajkumar, Advocate, referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.06.2024, submitted that, the assessment

ACIT, CIRCLE-2(1), HYDERABAD vs. HINDUJA NATIONAL POWER CORPORATION LIMITED, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleआ.अपी.सं / Ita No.235/Hyd/2023 (निर्धारण वर्ा / Assessment Year: 2016-17) The Assistant M/S. Hinduja National Power Commissioner Of Income Vs. Corporation Ltd. Tax, Circle 2(1), Hyderabad. Hyderabad. Pan : Aabch2426D अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Shri K. A. Sai Prasad, C.A. रधजस्‍व द्वधरध/Revenue By: Shri B. Bala Krishna, Cit-Dr.

disallowed and added back to the income returned. Addition: Rs. 271,70,42,063/- 13 Hinduja National Power Corporation Ltd. 7. The CIT-DR submitted that the scope and ambit of Section 32(1)(iia) of the Act, as well as Sections 32AC and 32AD, need to be examined. For this purpose, he drew our attention to the bare provisions

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE- 1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

8 are regarding the Investment Allowance claimed by the assessee u/s 32AC were disallowed by the Assessing Officer and confirmed by the learned CIT (A). 10. The learned AR has submitted that during the year under consideration, the assessee has claimed deduction of Rs.240 crores u/s 32AC(1) of the Act on the investment of Rs.1600/- crores made

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE-1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

8 are regarding the Investment Allowance claimed by the assessee u/s 32AC were disallowed by the Assessing Officer and confirmed by the learned CIT (A). 10. The learned AR has submitted that during the year under consideration, the assessee has claimed deduction of Rs.240 crores u/s 32AC(1) of the Act on the investment of Rs.1600/- crores made

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

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

8 are regarding the Investment Allowance claimed by the assessee u/s 32AC were disallowed by the Assessing Officer and confirmed by the learned CIT (A). 10. The learned AR has submitted that during the year under consideration, the assessee has claimed deduction of Rs.240 crores u/s 32AC(1) of the Act on the investment of Rs.1600/- crores made

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

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

8 are regarding the Investment Allowance claimed by the assessee u/s 32AC were disallowed by the Assessing Officer and confirmed by the learned CIT (A). 10. The learned AR has submitted that during the year under consideration, the assessee has claimed deduction of Rs.240 crores u/s 32AC(1) of the Act on the investment of Rs.1600/- crores made

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

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

8,77,278/- towards disallowance of interest on TDS and further disallowance of EPF & ESI under Section 36(1)(va) for Rs. 3,66,095/-, addition towards disallowance of interest expenditure under Section 36(1)(iii) for Rs. 11,08,678/-, disallowance of expenses claimed by the assessee under the head ‘trade discounts' and 'seed purchases' to the tune

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. RAMKY ENERGY AND ENVIRONMENT LTD, HYDERABAD

In the result, both the appeals filed by the Revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

disallowed the claim only on the basis of that the assessee has not entered into an agreement with the Karnataka State Pollution Control Board, Bangalore and also with the Tamilnadu State Pollution Control Board, Salem District. Though for both the places, the assessee was having consent / authorization to operate facility for collection / reception / treatment / storage/ transport and disposal

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3(1), HYDERABAD vs. RAMKY ENERGY AND ENVIRONMENT LIMITED, HYDERABAD

In the result, both the appeals filed by the Revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

disallowed the claim only on the basis of that the assessee has not entered into an agreement with the Karnataka State Pollution Control Board, Bangalore and also with the Tamilnadu State Pollution Control Board, Salem District. Though for both the places, the assessee was having consent / authorization to operate facility for collection / reception / treatment / storage/ transport and disposal

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)

13,765/-, respectively. 37. Insofar as the disallowance of sum of Rs. 2,76,00,000/- @ 30% of subcontract works for Rs. 9,20,00,000/-, we find that, the assessee has increased revenue and also expenditure by passing dummy entries for Rs. 9,20,00,000/- in the books of account without there being any actual payment

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)

13,765/-, respectively. 37. Insofar as the disallowance of sum of Rs. 2,76,00,000/- @ 30% of subcontract works for Rs. 9,20,00,000/-, we find that, the assessee has increased revenue and also expenditure by passing dummy entries for Rs. 9,20,00,000/- in the books of account without there being any actual payment

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)

13,765/-, respectively. 37. Insofar as the disallowance of sum of Rs. 2,76,00,000/- @ 30% of subcontract works for Rs. 9,20,00,000/-, we find that, the assessee has increased revenue and also expenditure by passing dummy entries for Rs. 9,20,00,000/- in the books of account without there being any actual payment

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

8 ITA.No.113/Hyd./2025 assessee has not incurred any expenditure, has made only ad-hoc disallowance of Rs.5,000/- under section 14A of the Act. The Assessing Officer and the learned CIT(A) without considering the relevant facts, has simply made disallowance under section 14A read with Rule 8D of I.T. Rules, 1962 and made addition of Rs.10

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

13 disallowance under section 44C of the Act, but not under section 40(a)(i) of the Act. According to her, not taking a ground under section 40(a)(i) of the Act amount to acceptance of disallowance under section 40(a)(i) of the Act and, therefore, such an addition cannot be deleted. 16. We have gone through

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

8 of the appellate order, which is to the following effect: 12. On perusal of the above, we find that the reliance placed by the Ld. First Appellate Authority on sub-clause (ii) of clause (a) of Section 143(1) is misplaced, since that clause is a general provision enabling correction of apparent mistakes in the return, whereas sub-clause