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

disallowance of interest reversal, stating it was a consequential adjustment to avoid double taxation.", "result": "Partly Allowed", "sections": [ "14A", "8D", "143(3)", "143(2)", "40(a)(ii)", "234B", "234C", "37", "10(34)", "57

FEDERATION OF AP COOPERATIVE URBAN BANKS AND CREDIT SOCIETIES LIMITED HYD,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.464/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Federation Of Ap Vs. Income Tax Officer Cooperative Urban Banks Ward 9(1) & Credit Societies Ltd. Hyderabad Hyd, Hyderabad Pan:Aaaaf7350F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri V. Ravish Bhatt, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 29/10/2025 घोषणा की तारीख/Pronouncement: 07/11/2025

disallowance of the deduction of Rs. 36,70,431/- claimed u/s 80P of the Act is not justified. 4. Further, without prejudice to Ground No. 2 and Ground No. 3 the income of the appellant is exempt as per the ‘Principle of Mutuality’ and hence the same is not liable tax. 5. Charging of interest

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)

disallowance of ‘site expenses’ of Rs. 44,24,840/- under Section 40(a)(ia) of the Act for non-deduction of TDS under Section 194C of the Act. 56. In the result, the appeal of the assessee for A.Y. 2019-20 is partly allowed. 57

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)

disallowance of ‘site expenses’ of Rs. 44,24,840/- under Section 40(a)(ia) of the Act for non-deduction of TDS under Section 194C of the Act. 56. In the result, the appeal of the assessee for A.Y. 2019-20 is partly allowed. 57

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)

disallowance of ‘site expenses’ of Rs. 44,24,840/- under Section 40(a)(ia) of the Act for non-deduction of TDS under Section 194C of the Act. 56. In the result, the appeal of the assessee for A.Y. 2019-20 is partly allowed. 57

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

57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges on altogether a different

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

57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges on altogether a different

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

57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges on altogether a different

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

57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges on altogether a different

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

57,98,232/- on funds diverted to other group companies and partly confirmed the addition made by the AO towards disallowance of finance charges. 27. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the ld. CIT(A) is erred in sustaining the addition made by the AO towards disallowance of finance charges on altogether a different

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

Section 36(1)(iii) of the Act. The learned CIT(A) has also\nconfirmed the addition made towards disallowance of seed\npurchases for Rs. 13,00,57

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

57(iii) of the Act, where the expression used is for the purpose of making or earning such income'. Section 14A of the Act on the other hand contains the expression 'in relation to income which does not form part of the total income.' The decision in Rajendra Prasad Moody (supra) cannot be used in the reverse to contend that

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DCIT, CIRCLE -2(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

SUSHEE INFRA & MINING LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(2), HYDERABAD vs. SUSHEE INFRA & MINING LIMITED, HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating

SUSHEE INFRA & MINING LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-(2), HYDERABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्‍यर्थी / Ita No. / A.Y. / Appellant / Respondent

disallowance made u/s 40(a)(ia) amounting to Rs.19,630/- is concerned, in our opinion, the assessee is entitled to get the deduction under section 80-IA(4) of the Act In view of the CBDT circular (supra). Ground raised by the assessee on this issue is decided accordingly. 55. Lastly coming to Ground No.2 of Revenue’s appeal relating