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

9) of the Income Tax Act, 1961.\n5. Your Appellant submits that the CIT(A) as well as the Assessing Officer disallowed\ninvestment allowance under section 32AC of Rs.240,00,69,986/- on assumption that\nelectricity is not an article or thing and also ignored the bills and certificates in support\nof acquisition and installation, on assumption, which

REASONING GLOBAL E-APPLICATIONS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2012-13 Reasoning Global E- Vs. Dy. C.I.T. Application Ltd, Hyderabad Circle 3(1) Pan:Aadcr6701P Hyderabad (Appellant) (Respondent) Assessee By: Shri Swapnil Deshmukh, Ca Revenue By: Shri Rohit Mujumdar, Dr Date Of Hearing: 07/06/2022 Date Of Pronouncement: 23/08/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.09.2017 Of The Learned Cit (A)-3, Hyderabad Relating To A.Y.2012-13. 2. Facts Of The Case, In Brief, Are That The Assessee Company Is Engaged In The Business Of Providing It Enabled Electronic Commerce Services. It Filed Its Return Of Income For The A.Y 2012-13 On 30.09.2012 Declaring Loss Of Rs.9,52,71,232/-. During The Course Of Assessment Proceedings, The Assessing Officer Noted That The Assessee Has Debited An Amount Of Rs.1,02,18,116/- Towards Web Hosting Charges. From The Bills/Invoices Produced For The Expenditure So Claimed, The Page 1 Of 19

section 9(1)(vi) of the Act, cannot make the assessee liable to deduct tax at source. In other words, the assessee is not liable to deduct withholding tax and such non deduction of withholding tax does not render the assessee in default and consequently, no disallowance

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

9. We have heard the rival contentions and also gone through the record in the light of the submissions made by either side. We have gone through the findings of Ld. DRP placed at page nos.84 & 85 of its order which is to the following effect : ITA No.912/Hyd/2024 11 9.1 We have also gone through the relevant portion of order

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

In the result, assessee's appeals for the A

9) of the Income Tax Act, 1961.\n5. Your Appellant submits that the CIT(A) as well as the Assessing Officer disallowed\ninvestment allowance under Section 32AC of Rs.240,00,69,986/- on assumption that\nelectricity is not an article or thing and also ignored the bills and certificates in support\nof acquisition and installation, on assumption, which

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

vi) "co-operative bank", "primary agricultural credit society" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of section 80P;] ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 20 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) (2) In making any deduction for a bad debt or part thereof

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

vi) "co-operative bank", "primary agricultural credit society" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of section 80P;] ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 20 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) (2) In making any deduction for a bad debt or part thereof

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

vi) "co-operative bank", "primary agricultural credit society" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of section 80P;] ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 20 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) (2) In making any deduction for a bad debt or part thereof

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

vi) "co-operative bank", "primary agricultural credit society" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of section 80P;] ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 20 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) (2) In making any deduction for a bad debt or part thereof

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

vi) "co-operative bank", "primary agricultural credit society" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of section 80P;] ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 20 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) (2) In making any deduction for a bad debt or part thereof

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

vi) "co-operative bank", "primary agricultural credit society" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of section 80P;] ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 20 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) (2) In making any deduction for a bad debt or part thereof

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

vi) "co-operative bank", "primary agricultural credit society" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of section 80P;] ITA Nos.1796/Hyd/2017, 241/Hyd/2018 Page 20 & 460 to 464/Hyd/2023 (S.A. Nos.63 to 67/Hyd/2023) (2) In making any deduction for a bad debt or part thereof

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

vi) will relate to cases covered under section 36(1)(viia) and has to be read with section 36(2)(v) of the Act. Thus, the proviso would not permit the benefit of double deduction, operating with reference to rural loans while, under section 36(1)(vii, the assessee would be entitled to general deduction upon an account having become

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

9,00,00,000 38,40,58,770 66,54,20,310 Own Funds NIL Sub Total 12,48,61,078 1,24,86,10,780 Total Investments at Cost (1+2+3) 1,49,50,90,780 Less: IND AS Fair Value adjustment 5,89,80,000 Total Investments as per Balance Sheet 1

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

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

vi) of the Act. Therefore, there was no question of writing off such interest as a bad debt. 9. In the hearing today, Ld. counsel for the appellant has referred to Section 21 of the Banking Regulation Act, 1949 and submits that under sub-section (1) thereof, all banking companies are bound to follow policy of the RBI so determined

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

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

vi) of the Act. Therefore, there was no question of writing off such interest as a bad debt. 9. In the hearing today, Ld. counsel for the appellant has referred to Section 21 of the Banking Regulation Act, 1949 and submits that under sub-section (1) thereof, all banking companies are bound to follow policy of the RBI so determined

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

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

vi) of the Act. Therefore, there was no question of writing off such interest as a bad debt. 9. In the hearing today, Ld. counsel for the appellant has referred to Section 21 of the Banking Regulation Act, 1949 and submits that under sub-section (1) thereof, all banking companies are bound to follow policy of the RBI so determined

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

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

vi) of the Act. Therefore, there was no question of writing off such interest as a bad debt. 9. In the hearing today, Ld. counsel for the appellant has referred to Section 21 of the Banking Regulation Act, 1949 and submits that under sub-section (1) thereof, all banking companies are bound to follow policy of the RBI so determined

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

9. Per contra, the Learned Departmental Representative (“Ld. DR”) supported the order of the Ld. First Appellate Authority and submitted that the CPC had rightly disallowed the deduction under Section 80P of the Act since the assessee failed to file its return within the due date prescribed under Section 139(1) of the Act. He contended that the disallowance

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

vi) will relate to cases covered under section\n36(1)(viia) and has to be read with section 36(2)(v) of the Act. Thus, the proviso would\nnot permit the benefit of double deduction, operating with reference to rural loans\nwhile, under section 36(1)(vii, the assessee would be entitled to general deduction\nupon an account having become