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 made by the Assessing Officer under Section 14A read with rule 8D is bad in law, as the Learned Assessing Officer failed to record his dissatisfaction with regard to the correctness of the appellant's claim, as required under Section 14A(2

THERMODYNE DYNAMICS PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD -17(3), HYDERABAD

Bench: Us :

disallowing Rs. 15,75,000/-under section 14A of the Act, under the facts and circumstances of the case. 5. Whether the learned Authorities below are justified in making the addition of an amount being Rs. 18,03,62,857/- under section 56[2

BALA REDDY GOPU, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD

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

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

section 14A r.w.r 8D(2)(iii) to enhance the income by making disallowance u/s 14A. Therefore, the disallowance made by the CIT(A) is, accordingly

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

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

section 14A of the Act read with rule 8D of the Rules are applicable to the facts of the case, and proceeded to make addition under 8D(2)(ii) of the Rules and 8D(2)(iii) of the Rules to reach the figure of disallowance

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

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

section 14A of the Act read with rule 8D of the Rules are applicable to the facts of the case, and proceeded to make addition under 8D(2)(ii) of the Rules and 8D(2)(iii) of the Rules to reach the figure of disallowance

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

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

section 14A of the Act read with rule 8D of the Rules are applicable to the facts of the case, and proceeded to make addition under 8D(2)(ii) of the Rules and 8D(2)(iii) of the Rules to reach the figure of disallowance

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 under Section 14A. Ground No. 9 The appellant craves leave to add, alter, amend, modify, substitute or delete any of the above grounds of appeal at or before the time of hearing. Ground No. 10 The learned CIT(A) erred in not appreciating that the A.O. did not record the requisite satisfaction as required under Section 14A(2

UNION BANK OF INDIA (ERSTWHILE-ANDHRA BANK),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Section 14A(2) of the Act, read with Rule 8D of the Rules, we also make it clear that before applying the theory of apportionment, the AO needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance

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

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आयकर अपीलसं./I.T.A. No.1083/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2017-18) Assistant Commissioner Of Income Tax, Circle-5(1), Hyderabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) Industries आयकर अपीलसं./I.T.A. No.1084/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2018-19) Assistant Commissioner Of Income Tax, Circle-5(1), Hydeabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Industries Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By : Shri Sourabh Soparkar, Advocate राजस्वकाप्रतिनिधित्व/ Department Represented By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing : 11/11/2025 घोषणा की तारीख/ Date Of Pronouncement : 21/01/2026 2

disallowance of Rs. 74.92 lacs made by the AO under Section 14A of the Act, uphold the same. The Grounds of appeal Nos. 1 & 2

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

disallowance of Rs. 74.92 lacs made by the AO under Section 14A of the Act, uphold the same. The Grounds of appeal Nos. 1 & 2

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD vs. UNION BANK OF INDIA, HYDERABAD

In the result, the appeal of revenue is partly allowed for statistical\npurposes

Section 14A(2) of the Act, read with Rule\n8D of the Rules, we also make it clear that before applying the theory of\napportionment, the AO needs to record satisfaction that having regard to the\nkind of the assessee, suo moto disallowance

ANANDA PRASAD VENIGALA,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1384/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Ananda Prasad Venigala, Dy. Commissioner Of Income Tax, Vs. Circle-1(1), Hyderabad. Hyderabad. Pan:Aewpp1096B (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By:: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 31/07/2025 घोर्णध की तधरीख/Pronouncement: 06/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Ananda Prasad Venigala (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 18.11.2024 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

disallowance is unjustified because the Ld. AO failed to record proper satisfaction, as required under Section 14A(2), before invoking

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:

2) of the Act was issued to the assessee on 07.08.2017. The Learned Assessing Officer (“Ld. AO”) completed the assessment under Section 143(3) of the Act on ITA No.1200/Hyd/2019 3 26.12.2018. While doing so, the Ld. AO made disallowances of Rs.27,464/- under Section 37(1) of the Act, disallowance of Rs.6,09,705/- out of miscellaneous expenditure

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

section 14A r.w.s.8D of Income Tax Rules, 1962, even though the assessee has not earned any dividend income, which is exempt u/s 10(34) of the Act. The Ld.CIT(A), after considering the relevant facts has rightly deleted the additions made by the A.O. Thus, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

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

section 14A r.w.s.8D of Income Tax Rules, 1962, even though the assessee has not earned any dividend income, which is exempt u/s 10(34) of the Act. The Ld.CIT(A), after considering the relevant facts has rightly deleted the additions made by the A.O. Thus, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

section 14A r.w.s.8D of Income Tax Rules, 1962, even though the assessee has not earned any dividend income, which is exempt u/s 10(34) of the Act. The Ld.CIT(A), after considering the relevant facts has rightly deleted the additions made by the A.O. Thus, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

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

section 14A r.w.s.8D of Income Tax Rules, 1962, even though the assessee has not earned any dividend income, which is exempt u/s 10(34) of the Act. The Ld.CIT(A), after considering the relevant facts has rightly deleted the additions made by the A.O. Thus, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal

ASIAN INSTITUTE OF GASTROENTEROLOGY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2020-2021 and 2021-2022 are allowed

Bench: Shri Manjunatha G & Shri Ravish Sood

disallowance under section 14A read with Rule 8D of I.T. Rules. Therefore, we cannot uphold the reasons given by the learned PCIT to set-aside the assessment order passed by the Assessing Officer for both the assessment years. 11. The assessee has relied upon the decision of Hon’ble Supreme Court in the case of Malabar Industrial Company Limited

SRI KSSV FINVEST PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. ITO, WARD-3(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 Sri Kssv Finvest Pvt. Ltd., Vs. Income-Tax Officer, Hyderabad. Ward – 3(3), Hyderabad. Pan – Aaack9655Q (Appellant) (Respondent)

14A of the Act provides that it mandates disallowance of expenditure 'in relation' to the income which does not form part of the total income under the Act while clause (f) in explanation1 to Section 115JB (2