BRIGHTCOM GROUP LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 37 of the Act towards CSR expenditure, Rs.2,07,247/- on account of disallowance towards prior period expenses and Rs.38 lakhs on account of non-reconciliation of income as per profit and ITA No.1747/Hyd/2019 14 loss account and form no.26AS. Accordingly, the Ld. AO computed the total income of the assessee at Rs.15,74,79,993/-. 6. Aggrieved with

SHELADIA ASSOCIATES INC,HYDERABAD vs. ADIT(INT TAXN)-2,HYD, HYDERABAD

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

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

section 143(3) r.w.s. 144C(13) of the Income tax Act, 1961 (“the Act”), assessee preferred this appeal. 2. Subject matter of this appeal are four additions in respect of disallowance of expenditure recorded as bad debts of Rs.16,97,639/-, disallowance of Rs.46,40,500/- claimed towards consultancy charges, disallowance of Rs.32,43,680/- claimed towards expenditure for third

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

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

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

disallowance of Rs.45,90,60,000 are incorrect and cannot be sustained.” 2.1. Thereafter, assessee has filed the following additional grounds which read as under : “1. The ld.AO and ld.CIT(A) have erred in making addition / sustaining addition of Rs.27,09,00,000/- in respect of unsold balance lands of Ac.6.18 guntas to Sri S. Narayana Reddy and others

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 by the Assessing Officer by holding that the generation of electricity is not production of any article or thing as per section 32AC of the I.T. Act, 1961 and therefore, in the Page 15 of 53 ITA Nos 283 284 286 and 300 301

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 by the Assessing Officer by holding that the generation of electricity is not production of any article or thing as per section 32AC of the I.T. Act, 1961 and therefore, in the Page 15 of 53 ITA Nos 283 284 286 and 300 301

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 by the Assessing Officer by holding that the generation of electricity is not production of any article or thing as per section 32AC of the I.T. Act, 1961 and therefore, in the Page 15 of 53 ITA Nos 283 284 286 and 300 301

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 by the Assessing Officer by holding that the generation of electricity is not production of any article or thing as per section 32AC of the I.T. Act, 1961 and therefore, in the Page 15 of 53 ITA Nos 283 284 286 and 300 301

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.283, 284 & 286/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F Vs. Acit, Circle - 1 Khammam & Acit, Circle 13(1) Hyderabad & आ.अपी.सं / Ita Nos.300, 301 & 308/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. Cit, Circle 13(1) Hyderabad (Appellant) Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / 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:

301 & 308/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. CIT, Circle 13(1) Hyderabad (Appellant) Singareni Collieries Company Limited Kothagudem PAN:AAACT8873F (Respondent) निर्धारिती द्वारा / Assessee by: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / 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

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

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

section 36(2)(v) of the Act, restricted the provision for bad and doubtful debts u/s 36(1)(viia) to the extent of actual provision created in the books of account. Therefore, the excess provision claimed in the revised computation of total income to the extent of Rs.265,71,57,198/- (Rs.847,40,27,692 – Rs.581

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

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

section 36(2)(v) of the Act, restricted the provision for bad and doubtful debts u/s 36(1)(viia) to the extent of actual provision created in the books of account. Therefore, the excess provision claimed in the revised computation of total income to the extent of Rs.265,71,57,198/- (Rs.847,40,27,692 – Rs.581

ALI MOHAMMED,HYDERABAD vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION)-1, HYDERABAD

Appeal is allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

301] (Bang) and Ms.Prema P.Shah Vs. ITO [100 ITD 60] hold in “pre- amendment era” that such a re-investment of capital gains in a residential house outside India is very much entitled for the impugned Section 54 relief. We thus reverse the learned lower authorities’ action disallowing

SUMATHI CORPORATE SERVICES PRIVATE LIMITED,HYDERABAD vs. ITO WARD-3(1), HYDERABAD

In the result, appeal of the assessee is dismissed

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

301/-. While processing such return under section 143(1) of the Act, CPC disallowed an amount of Rs. 1,52,80,431/- under

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

301 ITR 404 (Raj) 18. In the above cases, it has been unanimously held that provisions of section 68 can only be applied for the current year credits. Therefore, we affirm the view of the Ld. CIT(A) and delete the addition of Rs.91,32,966/-. 19. So far as the remaining credits of Rs.7,43,028/-, we remit

RADHIKA KURRA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2013-14 Radhika Kurra, Vs. Asst. Commissioner Of Hyderabad. Income-Tax, Circle – 2(2), Pan – Aedpk 3506Q Hyderabad. (Appellant) (Respondent) Assessee By: Shri Pvss Prasad Revenue By: Shri Sunil Kumar Pandey Date Of Hearing: 29/04/2021 Date Of Pronouncement: 20/07/2021

disallowed the exemption which was claimed under section 54F of the Act. 1.4 In this regard appellant would respectfully submit that, at the time of sale of the property, appellant was not in possession of more than one residential house as the villas handed over to appellant by Ambience Properties Limited are not in habitable condition and that they

KONDE NARASIMHA (HUF),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX , CIRCLE 8(1), HYDERABAD

In the result, all the appeals of the assessees are partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

disallowance of expenditure claimed by the respective assessees towards sale of their extent of land. 8. Aggrieved, the assessee is in second appeal before us by raising the following revised and additional grounds of appeal: “1. The order of the learned Commissioner of Income Tax (A) is against the law, weight Rs.1,82,82,192/- of evidence and probabilities

MALI NARASIMHA (HUF), R.R. DISTRICT,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessees are partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

disallowance of expenditure claimed by the respective assessees towards sale of their extent of land. 8. Aggrieved, the assessee is in second appeal before us by raising the following revised and additional grounds of appeal: “1. The order of the learned Commissioner of Income Tax (A) is against the law, weight Rs.1,82,82,192/- of evidence and probabilities

DAPPU NARASIMHA (HUF), RR DIST,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessees are partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

disallowance of expenditure claimed by the respective assessees towards sale of their extent of land. 8. Aggrieved, the assessee is in second appeal before us by raising the following revised and additional grounds of appeal: “1. The order of the learned Commissioner of Income Tax (A) is against the law, weight Rs.1,82,82,192/- of evidence and probabilities

SRI JILAKARA NARASIMHA, R.R. DIST,HYDERABAD vs. ACIT, CIRCLE -8(1),, HYDERABAD

In the result, all the appeals of the assessees are partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

disallowance of expenditure claimed by the respective assessees towards sale of their extent of land. 8. Aggrieved, the assessee is in second appeal before us by raising the following revised and additional grounds of appeal: “1. The order of the learned Commissioner of Income Tax (A) is against the law, weight Rs.1,82,82,192/- of evidence and probabilities

MALI CHANDRASEKHAR (HUF), R.R. DISTRICT,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessees are partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

disallowance of expenditure claimed by the respective assessees towards sale of their extent of land. 8. Aggrieved, the assessee is in second appeal before us by raising the following revised and additional grounds of appeal: “1. The order of the learned Commissioner of Income Tax (A) is against the law, weight Rs.1,82,82,192/- of evidence and probabilities