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)

Section 40(a)(ia) of the Act. Therefore, once again making disallowance of the said amount for the year under consideration is amounting to double addition, which is not permissible under the law. The learned counsel for the assessee further submitted that, in respect of subcontract works of Rs. 9

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)

Section 40(a)(ia) of the Act. Therefore, once again making disallowance of the said amount for the year under consideration is amounting to double addition, which is not permissible under the law. The learned counsel for the assessee further submitted that, in respect of subcontract works of Rs. 9

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)

Section 40(a)(ia) of the Act. Therefore, once again making disallowance of the said amount for the year under consideration is amounting to double addition, which is not permissible under the law. The learned counsel for the assessee further submitted that, in respect of subcontract works of Rs. 9

PRASAD FILM LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE-6(1), HYDERABAD

In the result appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

disallowance made by the Assessing Officer under section 14A read with Rule 8D of I.T. Rules, 1962 cannot be upheld. In this regard, he relied upon certain judicial precedents i.e., decision of Hon’ble Bombay High Court in the case of PCIT vs., Tata Capital Ltd., [2024] 161 taxmann.com 557 9

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 deduction under Section 80P of the Act cannot be made through adjustment under Section 143(1). Finally, the Ld. AR prayed before the Bench to delete the addition of Rs.36,70,431/-. Page 6 of 11 ITA No 464 of 2025 Federation of AP Coop Urban Banks and Credit Societies 9

JASPER INDUSTRIES PVT LTD,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed

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

disallowance under Section 14A. Ground No. 9 The appellant craves leave to add, alter, amend, modify, substitute or delete any of the above

NUNHEMS INDIA PRIVATE LIMITED,R.R.DIST vs. JCIT, RANGE 16, HYDERABAD

In the result, the assessee’s appeal for the A

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

disallowance u/s 40(a)(ia) is justified. Page 9 of 38 ITA Nos.290 of 2011 327 of 2012 and 1775 of 2013 Nunhems India, Medchal, RR Distt. 7.3 Having regard to the rival contentions and the material on record, we find that the AO has treated the payment as fee for technical services u/s 9

NUNHEMS INDIA PRIVATE LIMITED,,HYDERABAD vs. ASST.CIT,CIRCLE 16(1),,

In the result, the assessee’s appeal for the A

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

disallowance u/s 40(a)(ia) is justified. Page 9 of 38 ITA Nos.290 of 2011 327 of 2012 and 1775 of 2013 Nunhems India, Medchal, RR Distt. 7.3 Having regard to the rival contentions and the material on record, we find that the AO has treated the payment as fee for technical services u/s 9

NUNHEMS INDIA PVT.LTD.,,R.R.DIST vs. ADDL.CIT, RANGE-16, HYDERABAD

In the result, the assessee’s appeal for the A

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

disallowance u/s 40(a)(ia) is justified. Page 9 of 38 ITA Nos.290 of 2011 327 of 2012 and 1775 of 2013 Nunhems India, Medchal, RR Distt. 7.3 Having regard to the rival contentions and the material on record, we find that the AO has treated the payment as fee for technical services u/s 9

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

In the result, the appeal filed by the Revenue stands dismissed

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

section 40A(9) of the Act, which disallows contributions made by an employer to any fund, ITA Nos.285 & 307/Hyd/2024 10 trust

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

In the result, the appeal filed by the Revenue stands dismissed

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

section 40A(9) of the Act, which disallows contributions made by an employer to any fund, ITA Nos.285 & 307/Hyd/2024 10 trust

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

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

9 of 22 ITA No. 385 & 386/Hyd/2015 this finding of the learned CIT(A). We agree with the learned CIT(A) and reject this contention. 21. Coming to the last contention urged by the learned AR that the disallowance under section

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

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

9 of 22 ITA No. 385 & 386/Hyd/2015 this finding of the learned CIT(A). We agree with the learned CIT(A) and reject this contention. 21. Coming to the last contention urged by the learned AR that the disallowance under section

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

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

9 of 22 ITA No. 385 & 386/Hyd/2015 this finding of the learned CIT(A). We agree with the learned CIT(A) and reject this contention. 21. Coming to the last contention urged by the learned AR that the disallowance under section

N.A.M. EXPRESSWAY LIMITED,DELHI vs. DCIT, CIRCLE-5(1), HYDERABAD

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

Bench: the due date provided for filing return of income u/s 139(1) of the Act, which attracts the provisions section 43B, however, the said amount 3

9) of section 270A for under reporting of income, is in consequence of misreporting thereof and thus, the assessee is not entitled for immunity from penalty. The AO had also rejected the explanation of the assessee with regard to disallowance

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

9. 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 ground, even though, the AO disallowed interest on the ground that the appellant has not established utilization of advances from customers for the purpose

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

9. 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 ground, even though, the AO disallowed interest on the ground that the appellant has not established utilization of advances from customers for the purpose

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

9. 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 ground, even though, the AO disallowed interest on the ground that the appellant has not established utilization of advances from customers for the purpose

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

9. 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 ground, even though, the AO disallowed interest on the ground that the appellant has not established utilization of advances from customers for the purpose