DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD vs. MYLAN LABORATORIES LIMITED , HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

disallowing income-tax deduction for any kind of fine is not proper. g. Another noteworthy point is that the Explanation to section 37(1) is a deeming provision. It only creates a legal fiction. Next, the Explanation comes into play when expenditure, though incurred for business purpose, is coupled with purpose which is offence or prohibited by law. Here

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

1-3-1987 to the then Revenue\nSecretary requesting him to issue instructions to all the\nofficers concerned with land acquisition to deduct income-\ntax on payment of interest and to follow the provisions as\nlain down under section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest

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

In the result, assessee's appeals for the A

1-3-1987 to the then Revenue\nSecretary requesting him to issue instructions to all the\nofficers concerned with land acquisition to deduct income-\ntax on payment of interest and to follow the provisions as\nlaid down under section 194A and other provisions of the\nAct. In paragraph 2 of that D.O. letter, it was stated that\nwhile paying interest

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:

disallowed. …………………………………………………….. Page 38 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 9.5 We have considered the rival submissions and perused the material on record as well as gone through the orders of revenue authorities. The assessee has deposited the interest as per the court directions on the enhanced compensations

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:

disallowed. …………………………………………………….. Page 38 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 9.5 We have considered the rival submissions and perused the material on record as well as gone through the orders of revenue authorities. The assessee has deposited the interest as per the court directions on the enhanced compensations

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:

disallowed. …………………………………………………….. Page 38 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 9.5 We have considered the rival submissions and perused the material on record as well as gone through the orders of revenue authorities. The assessee has deposited the interest as per the court directions on the enhanced compensations

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:

disallowed. …………………………………………………….. Page 38 of 53 ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd 9.5 We have considered the rival submissions and perused the material on record as well as gone through the orders of revenue authorities. The assessee has deposited the interest as per the court directions on the enhanced compensations

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

199 ITR 43 (SC). Our submission: a. It is respectfully submitted, that the Ld. DR is misinterpreting the provisions of sub-section 5 of section 80-IA of the Act. The scope of section 80-IA(5) of the Act is limited only to the determination of the quantum of deduction u/s. 80-IA of the Act. And that provisions

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

199 ITR 43 (SC). Our submission: a. It is respectfully submitted, that the Ld. DR is misinterpreting the provisions of sub-section 5 of section 80-IA of the Act. The scope of section 80-IA(5) of the Act is limited only to the determination of the quantum of deduction u/s. 80-IA of the Act. And that provisions

S A BUILDERS & DEVELOPERS ,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-1(2) , HYDERABAD

In the result, Ground Nos

disallowance is called for u/s 40(a)(ia) of the Act. Even\notherwise, when the assessee has not paid the TDS amount in the\ngovt. account, then the recipient of the amount cannot avail the\nTDS credit being not reflected in 26AS. Accordingly, we do not\nfind any error or illegality in the impugned order of the learned\nCIT

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(1) , HYDERABAD vs. S A BUILDERS AND DEVELOPERS , HYDERABAD

The appeals of the Revenue are dismissed

disallowance is called for u/s 40(a)(ia) of the Act. Even\notherwise, when the assessee has not paid the TDS amount in the\ngovt. account, then the recipient of the amount cannot avail the\nTDS credit being not reflected in 26AS. Accordingly, we do not\nfind any error or illegality in the impugned order of the learned\nCIT

ACIT., CIRCLE-6(1), HYDERABAD vs. PATEL SEW JOINTVENTURE, HYDERABAD

In the result, the cross-objection filed by the assessee is dismissed

disallowance of deduction under Section 80-IA(4) of the Act, in light of the various arguments of the learned counsel for the assessee along with certain judicial precedents, including the decision of the ITAT, Mumbai Bench, in the case of Akry Organics Pvt. Ltd Vs. CPC (supra) and also the decision in the case of ACIT Vs. Rashmi Infrastructure

PATEL SEW JOINT VENTURE,TELANGANA vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, the cross-objection filed by the assessee is dismissed

disallowance of deduction under Section 80-IA(4) of the Act, in light of the various arguments of the learned counsel for the assessee along with certain judicial precedents, including the decision of the ITAT, Mumbai Bench, in the case of Akry Organics Pvt. Ltd Vs. CPC (supra) and also the decision in the case of ACIT Vs. Rashmi Infrastructure

MULAKALA MOHAN KRISHNA,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

1) of the Act, disallowed the deduction claimed under section 80IA of the Act on the ground that the audit report was not filed within the prescribed time. 7. Aggrieved with the order of CPC, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) upheld the action of the CPC. The observation

SREE NAGENDRA CONSTRUCTIONS,,KHAMMAM vs. DCIT, CIRCLE -2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

199\nITR\n(SC), the Hon'ble Court held that ITA\nNo.2620/Kol/2013 A.Y. 2010-11 ITO Wd-12(1), Kol. vs. M/s\nStandard Leather Pvt. Ltd. Page 15 cessation of liability for the\npurpose of section 41(1) means irrevocable cessation so that\nthere is no possibility of the liability being revived in future. If\nthere is such a possibility

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD, HYDERABAD

In the result, the appeal of assessee in ITA

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

disallowance of Rs.7,14,84,000/- made by the A.O. towards provisions for NPA assets. In the assessment order, the A.O. has stated that on perusal of the annual accounts, it is noticed that the appellant bank has reversed provision made towards NPA accounts during this year to the extent of Rs.7,14,84,000/-. Vide questionnaire dated

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD

In the result, the appeal of assessee in ITA

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

disallowance of Rs.7,14,84,000/- made by the A.O. towards provisions for NPA assets. In the assessment order, the A.O. has stated that on perusal of the annual accounts, it is noticed that the appellant bank has reversed provision made towards NPA accounts during this year to the extent of Rs.7,14,84,000/-. Vide questionnaire dated

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD

In the result, the appeal of assessee in ITA

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

disallowance of Rs.7,14,84,000/- made by the A.O. towards provisions for NPA assets. In the assessment order, the A.O. has stated that on perusal of the annual accounts, it is noticed that the appellant bank has reversed provision made towards NPA accounts during this year to the extent of Rs.7,14,84,000/-. Vide questionnaire dated

A.P. GRAMEENA VIKAS BANK,WARANGAL vs. DCIT CIRCLE 3(1), HYDERABAD, HYDERABAD

In the result, the appeal of assessee in ITA

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

disallowance of Rs.7,14,84,000/- made by the A.O. towards provisions for NPA assets. In the assessment order, the A.O. has stated that on perusal of the annual accounts, it is noticed that the appellant bank has reversed provision made towards NPA accounts during this year to the extent of Rs.7,14,84,000/-. Vide questionnaire dated