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

Bench: Us :

2)(viia) of the Act has been made available on the statute to discourage share transactions at a suppressed value, therefore, the fine distinction attempted to be drawn by the assessee’s counsel between a “fresh allotment” vis-a-vis “transfer of shares” is devoid and bereft of any substance. 17 Thermodyne Dynamics Private Limited Vs. ITO 16. We have

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

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

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

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

disallowance of Rs. 94,55,889/- are upheld and sustained. Accordingly. relevant grounds of appeal are dismissed and not allowed. 6. In result, the present appeal of the appellant is dismissed and not allowed.” 12. The assessee company, being aggrieved with the order of the CIT(A), has carried the matter in appeal before us. 13. We have heard

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

disallowed and added back in terms of Explanation 2 to Section 37(1) of the Act. The company can claim deduction for hundred percent of the donation of Rs. 1 crores paid to Prime Minister's National Relief Fund u/s 80G(2)(iiia) read with Section 80G(1)(i) of the Act. The company claim deduction to the extent

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

disallowed and added back in terms of Explanation 2 to Section 37(1) of the Act. The company can claim deduction for hundred percent of the donation of Rs. 1 crores paid to Prime Minister's National Relief Fund u/s 80G(2)(iiia) read with Section 80G(1)(i) of the Act. The company claim deduction to the extent

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

Appeal are dismissed

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

55,036/- as evidenced by the entries of cash outflows in the names of the employees found in the seized material against the gross unaccounted cash receipts from sale of spent solvents and scrap of Rs.1,10,89,415/- for arriving at the real income thereon. 3. In the facts and circumstances of the case

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

Appeal are dismissed

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

55,036/- as evidenced by the entries of cash outflows in the names of the employees found in the seized material against the gross unaccounted cash receipts from sale of spent solvents and scrap of Rs.1,10,89,415/- for arriving at the real income thereon. 3. In the facts and circumstances of the case

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

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

2) of the Act, read with Rule 8D of the Rules, we also make it clear that before applying the theory of apportionment, the AO needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance under Section 14A was not correct. It will be in those cases where the assessee in his return

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)

55. We have heard both parties, perused the material available on record and had gone through the orders of the authorities below. The A.O. had made addition of Rs. 44,24,840/- under Section 40(a)(ia) of the Act, being 30% of site expenses of Rs. 1,47,49,468/- debited to the Profit and Loss Account

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)

55. We have heard both parties, perused the material available on record and had gone through the orders of the authorities below. The A.O. had made addition of Rs. 44,24,840/- under Section 40(a)(ia) of the Act, being 30% of site expenses of Rs. 1,47,49,468/- debited to the Profit and Loss Account

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)

55. We have heard both parties, perused the material available on record and had gone through the orders of the authorities below. The A.O. had made addition of Rs. 44,24,840/- under Section 40(a)(ia) of the Act, being 30% of site expenses of Rs. 1,47,49,468/- debited to the Profit and Loss Account

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

2)(iiihk) and (iiihl) of the Act. (para 16) We are in agreement with such observations and findings of the Coordinate Bench of the Tribunal and while respectfully following the same, we hold that inasmuch as the assessee satisfied the conditions of section 80G of the Act, the assessee is entitled to claim deduction under section

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

2)(iiihk) and (iiihl) of the Act. (para 16) We are in agreement with such observations and findings of the Coordinate Bench of the Tribunal and while respectfully following the same, we hold that inasmuch as the assessee satisfied the conditions of section 80G of the Act, the assessee is entitled to claim deduction under section

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

In the result, the appeal of revenue is partly allowed for statistical\npurposes

2) of the Act, read with Rule\n8D of the Rules, we also make it clear that before applying the theory of\napportionment, the AO needs to record satisfaction that having regard to the\nkind of the assessee, suo moto disallowance under Section 14A was not\ncorrect. It will be in those cases where the assessee in his return

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance of Rs.173,15,46,253/- on account of debts written off by the assessee as per his observation under para No.2 of his consequential order dated 31/03/2016, which is reproduced as under : ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 6 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) “ 2. WRITE OFF OF AMOUNTS UNDER (ADWDRS} AMOUNT RS. 173,15,46,253/- On this

THE ANDHRA PRADESH STATE CO OPERATIVE BANK LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance of Rs.173,15,46,253/- on account of debts written off by the assessee as per his observation under para No.2 of his consequential order dated 31/03/2016, which is reproduced as under : ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 6 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) “ 2. WRITE OFF OF AMOUNTS UNDER (ADWDRS} AMOUNT RS. 173,15,46,253/- On this

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance of Rs.173,15,46,253/- on account of debts written off by the assessee as per his observation under para No.2 of his consequential order dated 31/03/2016, which is reproduced as under : ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 6 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) “ 2. WRITE OFF OF AMOUNTS UNDER (ADWDRS} AMOUNT RS. 173,15,46,253/- On this

THE ANDHRA PRADESH STATE COOPERATIVE BANK LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance of Rs.173,15,46,253/- on account of debts written off by the assessee as per his observation under para No.2 of his consequential order dated 31/03/2016, which is reproduced as under : ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 6 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) “ 2. WRITE OFF OF AMOUNTS UNDER (ADWDRS} AMOUNT RS. 173,15,46,253/- On this

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance of Rs.173,15,46,253/- on account of debts written off by the assessee as per his observation under para No.2 of his consequential order dated 31/03/2016, which is reproduced as under : ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 6 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) “ 2. WRITE OFF OF AMOUNTS UNDER (ADWDRS} AMOUNT RS. 173,15,46,253/- On this