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 under section 40(a)(ia) would not survive. Since this factual aspect requires verification with supporting documentary evidence, we deem it just and proper to remit this issue back to the file of the Ld. AO. The Ld. AO is directed to call for details, explanations, and supporting evidences from the assessee, verify the applicability of section 194A

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 under section 40(a)(ia) would not survive. Since this factual aspect requires verification with supporting documentary evidence, we deem it just and proper to remit this issue back to the file of the Ld. AO. The Ld. AO is directed to call for details, explanations, and supporting evidences from the assessee, verify the applicability of section 194A

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

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:

section 194A in respect of the interest on the fixed deposit made as per the directions of the Court and observed that tax would not be required to be deducted at source but the TDS is required once Page 43 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd the ownership

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. IL & FS ENGINEERING & CONSTRUCTIONS CO. LIMITED , HYDERABAD

section 194A are not applicable. The A.O. after\nconsidering the submissions of the assessee disallowed\nRs.4,63,85,362/- u/s 40(a)(ia) of the Act for non-deduction

IL & FS ENGINEERING AND CONSTRUCTION COMPANY LIMITED(FORMERLY MAYTAS INFRA LIMITED),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-9, HYDERABAD

section 194A are not applicable. The A.O. after\nconsidering the submissions of the assessee disallowed\nRs.4,63,85,362/- u/s 40(a)(ia) of the Act for non-deduction

INCOME TAX OFFICER, WARD-1(2), HYDERABAD vs. ATHENA GLOBAL TECHNOLOGIES LIMITED (FORMERLY M/S VJIL CONSULTING LIMITED), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

disallowed 50% of Rs.88,25,786/-, contending that no evidence of TDS has been produced. The assessee submitted before the Ld. CIT(A) that, as per the provision of section 194A

ATHENA GLOBAL TECHNOLOGIES LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(4), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

disallowed 50% of Rs.88,25,786/-, contending that no evidence of TDS has been produced. The assessee submitted before the Ld. CIT(A) that, as per the provision of section 194A

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-8(1), HYDERABAD

In the result, the ground nos

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

disallowed 50% of Rs.88,25,786/-, contending that no evidence of TDS has been produced. The assessee submitted before the Ld. CIT(A) that, as per the provision of section 194A

GLOBAL DEVELOPERS,NELLORE vs. DCIT, CIRCLE-1, NELLORE

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1683/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Global Developers, Vs. Dcit, Nellore. Circle-1, Pan: Aagfg8471R Nellore. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: None राज" व "ारा/Revenue By: Shri Sankar Pandi. P, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 28/01/2026 घोषणा की तारीख/Date Of 04/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

194A): Rs.35,85,844/-; (iii) fees for professional or technical services (under section 194J): Rs.6,000/-; and (iv) rent (under section 194I): Rs.1,55,880/-. In our view, as the assessee firm had failed to deposit tax deducted at source (TDS) of Rs.38,57,609/- (supra), therefore, the AO has rightly disallowed

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

disallowed its claim for carry forward loss of Rs. 27,58,236/-. 5. The AO observed that the information available on record revealed that the assessee company had contractual receipts of Rs. 3,20,42,152/- on which tax was deducted at source (TDS) under section 194C of the Act. As the assessee company had failed to come forth with

ACIT., CIRCLE-1(1), TIRUPATI vs. PONNAMBALAM KRISHNAN, CHITTOOR

In the result, the appeal of the revenue and cross objections of the assessee are partly allowed for statistical purposes in above terms

Bench: Shri Manjunatha G, Accountnat Member & Shri Prakash Chand Yadavआ.अपी.सं /Ita No.655/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2017-18) Asst. Commissioner Of Income Shri Ponnambalam Krishnan, Tax, Circle 1(1), Tirupati. Vs. Ekjambarakuppam, Chittoor, A.P. Pan : Bedpk5641B (Appellant) (Respondent) C.O. No.11/Hyd/2024 (Assessment Year:2017-18) (By Assessee) निर्धाररती द्वधरध/Assessee By: Shri E. Phalguna Kumar, C.A. रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala,Sr-Dr सुिवधई की तधरीख/Date Of 10/09/2024 Hearing: घोर्णध की रीख/Pronouncement: 20/09/2024

disallowance under section 40(a)(ia) of the Act. We observe that the Ld. CIT(A) had written a categorical finding that the assessee has paid interest to bank on term loan and overdraft. These repayments of interest on term loan and overdraft are not covered by the provisions of section 194A

SANGEETA AKKARAJU CHANDRASEKHAR,HYDERABAD vs. ITO., WARD-14(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: The Tribunal. The Assessee Has Filed An Affidavit In Support Of The Condonation Petition, Wherein She Has Mentioned The Reasons For The Delay & Submitted That The Delay Occurred Due To Factors Beyond Her Control, With No Deliberate Intention To Defer The Filing Of The Appeal. On The Other Hand, The Learned Senior A.R. For The Revenue, Shri Mathivanan, S.A. Did Not Strongly Oppose The Condonation Of Delay Petition Filed By The Assessee.

194A on interest income amounts to Rs. 5,50,967/- and purchase of immovable property under (SFT-012) amounts to Rs. 2,71,48,800/-. Therefore, the assessment has been reopened under Section 147 of the Act, and a notice under Section 148, along with reasons for reopening and a notice under Section 142(1) of the Act, was issued

SANGHI TEXTILES PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-3(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

194A under the Head “Other Income”. As per the information available on record, the appellant-company made investment in time deposits at Rs.19,54,348/- during F.Y. 2012-13. Since the 3 ITA.No.759/Hyd./2024 assessee failed to explain the source of cash received during the year under consideration, the Assessing Officer treated the whole amount of Rs.19

ANDHRA CARDIOLOGY ASSOCIATES PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(2), HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 143(3) of the Income Tax Act, 1961 (in short, “the Act”). 2. The appeal filed by the assessee is barred by limitation by 03 days. It has moved a condonation petition explaining reasons thereof. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay

AP TOURISM DEVELOPMENT CORPORATION LIMITED,VIJAYAWADA vs. DCIT, CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2017-18 A.P Tourism Development Vs. Dy. Cit Corporation Ltd, Circle 1(1) Vijayawada Hyderabad Pan:Aadca9817H (Appellant) (Respondent) Assessee By: Advocate R. Mohan Kumar Revenue By: Shri Kumar Aditya, Dr Date Of Hearing: 24/05/2023 Date Of Pronouncement: 24/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Ex-Parte Order Dated 13/02/2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2017-18. 2. Facts Of The Case, In Brief, Are That The Assessee Is An A.P State Government Corporation Incorporated Under The Companies Act, 1956 & Established With The Main Objective Of Developing Tourism Infrastructure In The State Of Andhra Pradesh. The Corporation Is A State Govt. Company Since 1976. It Filed Its Return Of Income Declaring Total Loss Of Rs.9,95,84,720/-. The Case Was Selected For Scrutiny Under Cass & Statutory Notices U/S 143(2) & 142(1) Were Issued & Delivered Electronically To The Page 1 Of 6

disallowed the excess claim of depreciation of Rs.56,04,368/-. The Assessing Officer further noted from the 26AS statement that the assessee has received the following amount during the year: S.No Description of the Section under which TDS Amount of income income received is made by the deductor received 1 Rental/lease 194IB 2,27,57,627 income 2 Interest 194A