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

disallowance of deduction under section 80-IA in respect of the sale of scrap and interest receipts is not sustainable. As a result, ground no 5 is allowed. 7. In result, the appeal is allowed.\" 36. The revenue aggrieved with the CIT(A) order has carried the matter in appeal before us. 37. Shri. Sourabh Soparkar, Senior Advocate

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

43) to include interest within the definition of \"tax\" for the purpose of Section 40(a)(ii) is a generally accepted interpretation for the deductibility of the original payment.\nHowever, the crux of the appellant's argument lies in the principle of reversal of a prior year's disallowance. The appellant is not claiming a deduction for interest paid

COROMANDEL INTERNATIONAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(2), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“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 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

disallowance under section 14A of the Act, while allowing the claim of the assessee on account of depreciation on non-compete fees and depreciation on royalty amounting to Rs.3,74,68,790/- and Rs.75,34,379/- respectively, and assessed the total income of the assessee at Rs.552,16,73,095/-. Page 3 of 17 Coromandel International Limited Vs. DCIT

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

43) to include interest\nwithin the definition of \"tax\" for the purpose of Section 40(a)(ii) is a generally\naccepted interpretation for the deductibility of the original payment.\nHowever, the crux of the appellant's argument lies in the principle of reversal\nof a prior year's disallowance. The appellant is not claiming a deduction for\ninterest paid

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

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

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No. 537/Hyd/2023 (धििाारण वर्ा / Assessment Year: 2021-22) Sheladia Associates Inc, Adit (Int Taxn)-2, Secunderabad Vs. Hyderabad [Pan No. Aafcs7792F] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

disallowance of expense under section 44C of the Act is concerned, the assessee under other expenses in the consolidated P&L Account reported expenses of Rs. 1,21,62,145/- allocated head office overheads and Rs. 1,60,78,394/- towards business development and marketing expenses. According to the assessee, the assessee had shown the general and administrative expenses

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

43,41,133/- booked by the assessee attracts the provisions of section 40(a)(ia) of the Act, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

43,41,133/- booked by the assessee attracts the provisions of section 40(a)(ia) of the Act, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

43,41,133/- booked by the assessee attracts the provisions of section 40(a)(ia) of the Act, and accordingly, completed the assessment u/s. 153A by making addition of Rs. 13,02,340/- on account of disallowance of expenditure u/s 40(a)(ia) of the Income Tax Act, 1961 and assessed the total income of the assessee at Rs.49

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

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

disallowed Rs. 1,52,31,379/-. 6. Further, learned Assessing Officer found that the assessee acquired Rs. 1,53,980/- shares of M/s. Ind-Barath Power Infra Ltd., at a premium of Rs. 240/- per share on 30/09/2006, which the assessee claims to have sold to the same company during the assessment year 2010-11 at the face value

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

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

disallowed Rs. 1,52,31,379/-. 6. Further, learned Assessing Officer found that the assessee acquired Rs. 1,53,980/- shares of M/s. Ind-Barath Power Infra Ltd., at a premium of Rs. 240/- per share on 30/09/2006, which the assessee claims to have sold to the same company during the assessment year 2010-11 at the face value

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

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

disallowed Rs. 1,52,31,379/-. 6. Further, learned Assessing Officer found that the assessee acquired Rs. 1,53,980/- shares of M/s. Ind-Barath Power Infra Ltd., at a premium of Rs. 240/- per share on 30/09/2006, which the assessee claims to have sold to the same company during the assessment year 2010-11 at the face value

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

6) of section 43.\nExplanation 3.—For the purposes of this sub-section, the\nexpression "assets" shall mean—(a)tangible assets, being\nbuildings, machinery, plant or furniture;(b)intangible assets,\nbeing know-how, patents, copyrights, trademarks, licences,\nfranchises or any other business or commercial rights of\nsimilar nature [, not being goodwill of a business or\nprofession].\nExplanation

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

disallowance of deduction under section 80-IA\nin respect of the sale of scrap and interest receipts is not sustainable.\nAs a result, ground no 5 is allowed.\n7. In result, the appeal is allowed.\"\n36. The revenue aggrieved with the CIT(A) order has carried the\nmatter in appeal before us.\n37.\nShri. Sourabh Soparkar, Senior Advocate

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22,428/- confirmed by the ld.CIT(A) under Section 36(1)(iii) of the Income Tax Act, 1961. During the course of the assessment proceedings, the AO noticed that the real estate

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22,428/- confirmed by the ld.CIT(A) under Section 36(1)(iii) of the Income Tax Act, 1961. During the course of the assessment proceedings, the AO noticed that the real estate

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22,428/- confirmed by the ld.CIT(A) under Section 36(1)(iii) of the Income Tax Act, 1961. During the course of the assessment proceedings, the AO noticed that the real estate

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22,428/- confirmed by the ld.CIT(A) under Section 36(1)(iii) of the Income Tax Act, 1961. During the course of the assessment proceedings, the AO noticed that the real estate

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

6. The solitary issue that came up for our consideration in Ground Nos.2 to 4 of the assessee's appeal is the disallowance of finance charges of Rs.54,22,428/- confirmed by the ld.CIT(A) under Section 36(1)(iii) of the Income Tax Act, 1961. During the course of the assessment proceedings, the AO noticed that the real estate

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

In the result, assessee's appeals for the A

6) of section 43.\nExplanation 3.—For the purposes of this sub-section, the\nexpression \"assets\" shall mean—(a)tangible assets, being\nbuildings, machinery, plant or furniture;(b)intangible assets,\nbeing know-how, patents, copyrights, trademarks, licences,\nfranchises or any other business or commercial rights of\nsimilar nature [, not being goodwill of a business or\nprofession].\nExplanation