SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE- 1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10B (8) as being mandatory also has no substance. As observed hereinabove, the exemption provisions are to be strictly and literally complied with and the same cannot be construed as procedural requirement." 25. Similarly, in the case of Commissioner of Customs Vs. Dilip Kumar (supra), the Hon'ble Supreme Court in paragraph 40 has held as under : "40. After considering

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

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10B (8) as being mandatory also has no substance. As observed hereinabove, the exemption provisions are to be strictly and literally complied with and the same cannot be construed as procedural requirement." 25. Similarly, in the case of Commissioner of Customs Vs. Dilip Kumar (supra), the Hon'ble Supreme Court in paragraph 40 has held as under : "40. After considering

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

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10B (8) as being mandatory also has no substance. As observed hereinabove, the exemption provisions are to be strictly and literally complied with and the same cannot be construed as procedural requirement." 25. Similarly, in the case of Commissioner of Customs Vs. Dilip Kumar (supra), the Hon'ble Supreme Court in paragraph 40 has held as under : "40. After considering

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE-1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

10B (8) as being mandatory also has no substance. As observed hereinabove, the exemption provisions are to be strictly and literally complied with and the same cannot be construed as procedural requirement." 25. Similarly, in the case of Commissioner of Customs Vs. Dilip Kumar (supra), the Hon'ble Supreme Court in paragraph 40 has held as under : "40. After considering

ACIT, CIRCLE-2(1), HYDERABAD vs. HINDUJA NATIONAL POWER CORPORATION LIMITED, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleआ.अपी.सं / Ita No.235/Hyd/2023 (निर्धारण वर्ा / Assessment Year: 2016-17) The Assistant M/S. Hinduja National Power Commissioner Of Income Vs. Corporation Ltd. Tax, Circle 2(1), Hyderabad. Hyderabad. Pan : Aabch2426D अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Shri K. A. Sai Prasad, C.A. रधजस्‍व द्वधरध/Revenue By: Shri B. Bala Krishna, Cit-Dr.

property. Following the same logic, to deny the benefit of additional depreciation to a generating entity on the basis that electricity is not an "article" or "thing" is in our view an artificially restrictive meaning of the provision. The benefit of additional depreciation under Section 32(1)(iia) has, therefore, been rightly granted to the assessee by the concurrent judgments

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

Housing Boards, Public Works Department,\netc., acquire immovable property from the public for the\npurpose of their developmental activities. Huge amounts are\ndisbursed on behalf of these departments as payments of\ncompensation for land acquired including considerable\namount of interest on excess compensation as per the Land\nAcquisition Act. The interest payment made under the Land\nAcquisition Act are covered

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

In the result, assessee's appeals for the A

10B (8) as being\nmandatory also has no substance. As observed hereinabove,\nthe exemption provisions are to be strictly and literally\ncomplied with and the same cannot be construed as\nprocedural requirement.\"\n25. Similarly, in the case of Commissioner of Customs Vs.\nDilip Kumar (supra), the Hon'ble Supreme Court in paragraph\n40 has held as under :\n\"40. After

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

property of Indian Railways and the Government of India by default and any development 'with regard to the Railway Infrastructure cannot be done without the approval of the Indian Railways. Thus by default all the development of infrastructure has to have an explicit approval of the Indian Railways as per the above OM. Coming back to the decision

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

property of Indian Railways and the Government of India by default and any development 'with regard to the Railway Infrastructure cannot be done without the approval of the Indian Railways. Thus by default all the development of infrastructure has to have an explicit approval of the Indian Railways as per the above OM. Coming back to the decision

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

10B.\n11. Without prejudice to other grounds, the Ld. CIT(A) erred in not\nappreciating that the entire amount of Rs 20,97,19,672/-has been\nduly expended towards the objects of the trust on Revenue account\nwhich is clearly evident from the Return of Income filed.\n12.1. Without prejudice to other grounds, the Ld. CIT(A) ought

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

10B.\n11. Without prejudice to other grounds, the Ld. CIT(A) erred in not\nappreciating that the entire amount of Rs 20,97,19,672/-has been\nduly expended towards the objects of the trust on Revenue account\nwhich is clearly evident from the Return of Income filed.\n12.1. Without prejudice to other grounds, the Ld. CIT(A) ought

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

10B.\n11. Without prejudice to other grounds, the Ld. CIT(A) erred in not\nappreciating that the entire amount of Rs 20,97,19,672/-has been\nduly expended towards the objects of the trust on Revenue account\nwhich is clearly evident from the Return of Income filed.\n12.1. Without prejudice to other grounds, the Ld. CIT(A) ought

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

property transferred or services provided in a comparable uncontrolled transaction, or a number of such transactions, is identified; Emphasis is on comparable uncontrolled transactions or a number of transactions - hence median price for other parties charged by power unit is CUP and the AO was right in applying the same. Para 6.5.7 of the TPO order ( page

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, three appeals i

10B.\n11.\nWithout prejudice to other grounds, the Ld. CIT(A) erred in not\nappreciating that the entire amount of Rs 20,97,19,672/-has been\nduly expended towards the objects of the trust on Revenue account\nwhich is clearly evident from the Return of Income filed.\n12.\n12.1.\n12.2.\n12. Appellant may, add or alter or amend

MARRI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B of the Income Tax Rules, 1962. Further, the appellant society was regularly filing return of income under Section 139(1) of the Act, and also maintaining regular books of accounts for relevant assessment years. Further, for few assessment years, the case of the appellant was subjected to scrutiny assessment, where there was no adverse inference

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B of the Income Tax Rules, 1962. Further, the appellant society was regularly filing return of income under Section 139(1) of the Act, and also maintaining regular books of accounts for relevant assessment years. Further, for few assessment years, the case of the appellant was subjected to scrutiny assessment, where there was no adverse inference against the books

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B of the Income Tax Rules, 1962. Further, the appellant society was regularly filing return of income under Section 139(1) of the Act, and also maintaining regular books of accounts for relevant assessment years. Further, for few assessment years, the case of the appellant was subjected to scrutiny assessment, where there was no adverse inference against the books

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

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

10B of the Income Tax Rules, 1962. Further, the appellant society was regularly filing return of income under Section 139(1) of the Act, and also maintaining regular books of accounts for relevant assessment years. Further, for few assessment years, the case of the appellant was subjected to scrutiny assessment, where there was no adverse inference against the books

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

10B of the Income Tax Rules, 1962. Further, the appellant society was regularly filing return of income under Section 139(1) of the Act, and also maintaining regular books of accounts for relevant assessment years. Further, for few assessment years, the case of the appellant was subjected to scrutiny assessment, where there was no adverse inference against the books