SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

Disallowance of CSR expenses of Rs. 1,42,97,133/- against the returned income of Rs. 50,81,16,931/-. 2.1 Feeling aggrieved, the assessee raised certain objections before the Ld. DRP. The Ld. DRP, after considering the submissions of the assessee and also going through the material available on record, dismissed the objections raised by the assessee. Thereafter

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

10,11,500/-; (ii). disallowance of the claim of the assessee company\nfor deduction under section 80G in respect of donations forming part of\nCSR expenditure, holding that CSR expenditure being mandatory in\nnature could not qualify for deduction under section 80G except in\ncases specifically provided: Rs. 1,85,88,450/-; (iii). an estimated\ndisallowance

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, MADHAPUR

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

10. We next examine the merits of the assessee's claim in light of section 80IA(4) r.w. Explanation ( c ) thereof. This is for the reason that the legislature has reintroduced the Explanation; formerly inserted by the Finance Act, 2007 w.e.f. 1.4.2007 that "For the removal of doubts, it is hereby declared that nothing contained in this section shall apply

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

In the result, appeal of the Assessee is partly\nallowed for statistical purposes

sections": [ "143(3)", "144C(13)", "144C(5)", "80IA", "92BA", "801A(10)", "92C(3)", "92D", "10D", "115JAA", "234A", "234B", "153" ], "issues": "The primary issues involved are the validity of the assessment order due to limitation, disallowance

ACIT., CENTRAL CIRCLE-2(2), HYDERABAD vs. M/S KMC CONSTRUCTIONS LTD, HYDERABAD

disallowed the claim of the assessee company for deduction under Section 801A of the Act to keep the issue alive.\n11. Per Contra, Shri. S. Rama Rao, the learned Authorized Representative for the assessee company (for short, “AR”), on the other hand relied on the order of the CIT(A) and the consistent decisions of the Tribunal in assessee

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, HYDERABAD

In the result, all the appeals of the Revenue are dismissed

section 801A of the Act\ndecision (supra). We are afraid that such a liberal interpretation would\namount to going against the stricter interpretation principle in view of\nhonourable apex court decision (supra). We accordingly conclude both the\nlearned lower authorities have rightly disallowed assessee's 801A\ndeduction claim involving varying sum(s) (supra) in their respective\norders. The same stands

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(4), HYDERABAD

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

Bench: Shri Manjunatha G. Hon’Ble & Shri K. Narasimha Chary, Hon’Bleassessment Year – 2017-18 Prathima Infrastructure Limited, Vs. The Assistant Commissioner Of Income Tax, Filmnagar, Central Circle – 2(4), Hyderabad. Hyderabad. Pan : Aabcp2098P. (Respondent) (Appellant) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri B. Bala Krishna, Cit-Dr Date Of Hearing: 10.10.2024 Date Of Pronouncement: 27.11.2024

10 project, The above work is obtained from HCC a public limited company. Thus the basic condition required for claiming deduction under section 801A(4) of the Act is not fulfilled. The work contract Pranahitha-Chevella Lift irrigation scheme link-IV, package No.10 is actually awarded to M/s.HCC-MEIL-BHEL(Joint Venture) from the Government of Andhra Pradesh, Irrigation & C.A.D. Department vide

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, HYDERABAD

In the result, both the appeals filed by the assessee are partly allowed for statical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

801A(4) in respect of electrical projects also. 7. Your Appellant submits that a direction may be given to the Assessing Officer to consider all the disallowance as part of the gross General computing the deduction under section 80IA(4) Income Tax Act, 1961”. Page 27 of 29 ITA Nos 695 and 696 of 2020 GVPR Engineers Ltd Hyderabad

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 (3), HYDERABAD

In the result, both the appeals filed by the assessee are partly allowed for statical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

801A(4) in respect of electrical projects also. 7. Your Appellant submits that a direction may be given to the Assessing Officer to consider all the disallowance as part of the gross General computing the deduction under section 80IA(4) Income Tax Act, 1961”. Page 27 of 29 ITA Nos 695 and 696 of 2020 GVPR Engineers Ltd Hyderabad

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

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

10% without examining the period the said asset was put to use. It is evident that the disallowance was made an ad-hoc basis without any justification and there is no scope for such ad-hoc disallowances when the search assessment was being framed u/s.153A. Therefore, the AO is directed to delete the disallowance of depreciation of Rs.1

VALUELABS LLP,HYDERABAD vs. DCIT., CENTRAL CIRCLE 8(1), HYDERABAD

In the result, we uphold the order passed by the CIT(A) and\ndismiss the assessee's appeal

10%. The Assessing Officer (AO) disallowed this, stating that Section 115BBG applies only to 'carbon credits' and not RECs. The CIT(A) upheld the AO's order.", "held": "The Tribunal held that the definition of 'carbon credit' in Section 115BBG is precise and restrictive, requiring validation under the UNFCC mechanism for reduction of carbon dioxide emissions. RECs, issued under