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

32. Succinctly stated, the assessee company had filed its return of income for AY 2018-19 under section 139(1) of the Act on 30.11.2018, declaring an income of Rs.141,83,11,120/-, and “book profit” under Section 115JB of the Act of Rs. 230,21,15,364/-. Subsequently, the case of the assessee company was selected for complete scrutiny

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.

section 32(1)(iia) was disallowed as the assessee was entitled to depreciation only at 20% for assets used for less than 180 days, instead of the claimed 35%. Consequently, these disallowances were added back to the income returned, concluding the assessment with substantial adjustments. Thus, Assessing Officer completed the assessment u/s 143(3) of the Act dated

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

section 80G of the Act in respect of such donations which\nformed part of the spend towards CSR. Respectfully following the\njurisdictional tribunal, ground no 3 is allowed.\n5. Ground No.4 is raised against disallowance of business expenses\non estimate basis amounting to Rs.16,31,00,000/- on account of\ndeduction U/s 80IA. During the assessment proceedings, the AO\ncalled

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

Bench: Us :

disallowance u/s 56(2)(viia) of the Act was called for in the case of the assessee company. 21. Apropos the claim of the Ld. AR that as the assessee company had entered into an “agreement”, dated 18.02.2010 for subscription of shares of the aforementioned company, viz. M/s. Kineta Metals and Minerals Limited (supra) which was before the insertion

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeal of assessee in ITA No

disallowance of claim of deduction of expenditure against the unaccounted cash receipts from sale of spent solvents / scrap. The facts with regard to the impugned dispute are that the assessee is engaged in the manufacturing and sale of bulk drugs. In the process, the assessee purchased various solvents and used them for manufacturing bulk drugs. The used solvents

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

32,72,843 | 9,03,945 | 82,37,30,191 |\n5. 2. During the course of assessment proceedings, in the written submissions furnished to the AO on 21-4-2022 in response to notice under Section 142(1) of the Act, the appellant reiterated the explanation furnished by MSN Reddy, the Managing Director of the appellant company, in the sworn

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

32(1)(iia) of the Act, no corresponding amendment is made\nin section 32AC of the Act and therefore, the intention of the\nLegislature is clear that the benefit of section 32AC(1) is not\navailable to a company engaged in the business of generation of\npower. To maintain the rule of consistency, we follow the earlier\ndecision

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

In the result, assessee's appeals for the A

32(1)(iia) of the Act, no corresponding amendment is made\nin section 32AC of the Act and therefore, the intention of the\nLegislature is clear that the benefit of section 32AC(1) is not\navailable to a company engaged in the business of generation of\npower. To maintain the rule of consistency, we follow the earlier\ndecision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

ACIT., CENTRAL CIRCLE-2(4), , HYDERABAD vs. M/S. MAITHRI LABORATORIES PRIVATE LIMITED, HYDERABAD

In the result, both the appeals of assessee and the Revenue\nare partly allowed

disallowance of claim of deduction of\nexpenditure against the unaccounted cash receipts from sale of\nspent solvents / scrap. The facts with regard to the impugned\ndispute are that the assessee is engaged in the manufacturing and\nsale of bulk drugs. In the process, the assessee purchased various\nsolvents and used them for manufacturing bulk drugs. The used\nsolvents

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

disallowance of expenditure incurred in relation to payment of service charges in pursuance to service agreement between the appellant society and M/s. SKCMET even though the appellant society has demonstrated with evidences that the payment made to above two companies is commensurate with the services rendered by above two companies and there is no excessive and unreasonable payment to benefit

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

disallowed the assessee’s claim for deduction under section 80C of the Act of Rs. 66,982/-. 6. Accordingly, the AO vide his order under section 147 of the Act, dated 26/03/2025, determined the income of the assessee at Rs. 8,35,157/-. 7. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

disallowed the assessee’s claim for deduction under section 80C of the Act of Rs. 66,982/-. 6. Accordingly, the AO vide his order under section 147 of the Act, dated 26/03/2025, determined the income of the assessee at Rs. 8,35,157/-. 7. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. M/S. MSN LIFE SCIENCES PVT. LTD., HYDERABAD

disallowance of claim of deduction of expenditure against\nthe unaccounted cash receipts from sale of spent solvents / scrap.\nThe facts with regard to the impugned dispute are that the assessee\nis engaged in the manufacturing and sale of bulk drugs. In the\nprocess, the assessee purchased various solvents and used them for\nmanufacturing bulk drugs. The used solvents

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. MSN PHARMACHEM PVT. LTD., HYDERABAD

In the result, the appeal of assessee in ITA No

disallowance of claim of deduction of expenditure against\nthe unaccounted cash receipts from sale of spent solvents / scrap.\nThe facts with regard to the impugned dispute are that the assessee\nis engaged in the manufacturing and sale of bulk drugs. In the\nprocess, the assessee purchased various solvents and used them for\nmanufacturing bulk drugs. The used solvents

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeal of assessee in ITA No

disallowance of claim of deduction of expenditure against\nthe unaccounted cash receipts from sale of spent solvents / scrap.\nThe facts with regard to the impugned dispute are that the assessee\nis engaged in the manufacturing and sale of bulk drugs. In the\nprocess, the assessee purchased various solvents and used them for\nmanufacturing bulk drugs. The used solvents