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

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आयकर अपीलसं./I.T.A. No.1083/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2017-18) Assistant Commissioner Of Income Tax, Circle-5(1), Hyderabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) Industries आयकर अपीलसं./I.T.A. No.1084/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2018-19) Assistant Commissioner Of Income Tax, Circle-5(1), Hydeabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Industries Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By : Shri Sourabh Soparkar, Advocate राजस्वकाप्रतिनिधित्व/ Department Represented By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing : 11/11/2025 घोषणा की तारीख/ Date Of Pronouncement : 21/01/2026 2

section 80G of the Act in respect of such donations which formed part of the spend towards CSR. Respectfully following the jurisdictional tribunal, ground no 3 is allowed. 5. Ground No.4 was raised against the disallowance of deduction u/s 80IA amounting to Rs.24,35,05,411/-. The company is engaged in the business of manufacturing of cement and generation

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(1), HYDERABAD vs. ACP INDUSTRIES LIMITED, HYDERABAD

Appeals are treated as allowed for statistical purposes in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahuappellant Respondent

Section 14A disallowance of Rs.23,98,438/-, notional interest disallowance/addition of Rs.1,92,67,755/-, un-accounted income of Rs.6

ACP INDUSTRIES LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

Appeals are treated as allowed for statistical purposes in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahuappellant Respondent

Section 14A disallowance of Rs.23,98,438/-, notional interest disallowance/addition of Rs.1,92,67,755/-, un-accounted income of Rs.6

NMDC LIMITED,HYDERABAD vs. DCIT CIRCLE 5(1), HYDERABAD, HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1523/Hyd./2025 Assessment Year 2024-2025 Nmdc Limited, The Dcit, Hyderabad – 500028. Vs. Circle-5(1), Pan Aaacn7325A Hyderabad. Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Darshan Jakharia राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 16.02.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

disallowance amounting to Rs.4,57,60,72,841/- under section 438 is reported which is computed by considering the amounts

MEDHA SERVO DRIVES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(4), HYDERABAD

Appeals are allowed in above terms

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

438, 439 & 440/Hyd/2020 2. We notice at the outset with the able assistance of both the parties that the assessee’s identical sole substantive grievance herein seeks to reverse both the lower authorities’ action making Section 14A r.w.Rule 8D disallowance

MEDHA SERVO DRIVES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(4), HYDERABAD

Appeals are allowed in above terms

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

438, 439 & 440/Hyd/2020 2. We notice at the outset with the able assistance of both the parties that the assessee’s identical sole substantive grievance herein seeks to reverse both the lower authorities’ action making Section 14A r.w.Rule 8D disallowance

MEDHA SERVO DRIVES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(4), HYDERABAD

Appeals are allowed in above terms

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

438, 439 & 440/Hyd/2020 2. We notice at the outset with the able assistance of both the parties that the assessee’s identical sole substantive grievance herein seeks to reverse both the lower authorities’ action making Section 14A r.w.Rule 8D disallowance

OCEAN SPARKLE LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-16(3), HYDERABAD, HYDERABAD

In the result, both the appeals for AY 2011-12 and 2012-

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

section 14A provide for not allowing deduction in 13 I.T.A. Nos. 438 to 440/Hyd/2016 Ocean Sparkle Ltd., Hyd. respect of expenditure incurred by the assessee in relation to exempt income. The AR filed a detailed submission of the loans attributable to investment. The AO worked out the interest payable on the loans at Rs. 25,95,980/-, which was disallowed

OCEAN SPARKLE LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-16(3), HYDERABAD, HYDERABAD

In the result, both the appeals for AY 2011-12 and 2012-

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

section 14A provide for not allowing deduction in 13 I.T.A. Nos. 438 to 440/Hyd/2016 Ocean Sparkle Ltd., Hyd. respect of expenditure incurred by the assessee in relation to exempt income. The AR filed a detailed submission of the loans attributable to investment. The AO worked out the interest payable on the loans at Rs. 25,95,980/-, which was disallowed

OCEAN SPARKLE LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-16(3), HYDERABAD, HYDERABAD

In the result, both the appeals for AY 2011-12 and 2012-

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

section 14A provide for not allowing deduction in 13 I.T.A. Nos. 438 to 440/Hyd/2016 Ocean Sparkle Ltd., Hyd. respect of expenditure incurred by the assessee in relation to exempt income. The AR filed a detailed submission of the loans attributable to investment. The AO worked out the interest payable on the loans at Rs. 25,95,980/-, which was disallowed

INCOME TAX OFFICER, WARD-16(2), HYDERABAD vs. PADMASRI TOWNSHIPS PRIVATE LIMITED, , HYDERABAD

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

section 40A(3) of the Act. The appellant is found to have made payments in cash while purchasing the land from the sellers over and above Rs.20,000/-, aggregating of such amounts works out to Rs.3,65,29,360/- (Rs.3,38,29,360 + Rs.27,00,000) and disallowed the 100% of such amount for the year under consideration

SDE ENGINEERS PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. ITO, WARD-3(1), HYDERABAD, HYDERABAD

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 14A r.w. rule 8D he disallowed an amount of Rs.61,17,749/-. 22. In appeal, the learned CIT (A) sustained the addition made by the Assessing Officer. 23. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal. 24. The learned Counsel for the assessee referring to the decision

SDE ENGINEERS PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 14A r.w. rule 8D he disallowed an amount of Rs.61,17,749/-. 22. In appeal, the learned CIT (A) sustained the addition made by the Assessing Officer. 23. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal. 24. The learned Counsel for the assessee referring to the decision

SDE ENGINEERS PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 14A r.w. rule 8D he disallowed an amount of Rs.61,17,749/-. 22. In appeal, the learned CIT (A) sustained the addition made by the Assessing Officer. 23. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal. 24. The learned Counsel for the assessee referring to the decision

MYLAN LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER INCOME TAX , CIRCLE-5 (1) , HYDERABAD

In the result, the ground no

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

disallowance of the liquidated damages of Rs. 6.19 crores paid to Fresenius. 5. Coming first to Ground Nos. 1 to 3, the Ld. AR made detail submission with regards to their objection towards the invocation of section 263 by the Ld. PCIT. The relevant portion of submission made by Ld. AR dated 29/09/2023 in this regards is reproduced as under

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD vs. GVK TECHNICAL & CONSULTANCY PRIVATE LIMITED, SECUNDERABAD

In the result, appeal of the Revenue is dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2013-14

438 of the act by the Finance Act 2003 is not applicable to section 36(1)(va) since the amended section 43 applies only to employers contribution and not to employees contribution. 3. Any other ground that may be urged at the time of hearing.” 5. Considered the rival submissions and perused the material on record. We find that

PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

438/-. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT (A) and such appeal has been filed on 16/05/2023. During the course of appellate proceedings, the assessee has submitted the reasons for delay in filing of the appeal and claimed that, the assessment order dated 12/12/2019 was passed without the knowledge of the assessee

PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

438/-. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT (A) and such appeal has been filed on 16/05/2023. During the course of appellate proceedings, the assessee has submitted the reasons for delay in filing of the appeal and claimed that, the assessment order dated 12/12/2019 was passed without the knowledge of the assessee

SHIVAKUMAR BHUMAYYA,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda

disallowing the deduction claimed of Rs.2,28,187 towards PF and ESI which were otherwise allowable under the provisions of section 438