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:

3 months and 7 years and with fine. 2. It has come to notice that various State Development Authorities, the Housing Boards, Public Works Department, etc., acquire immovable property from the public for the purpose of their developmental activities. Huge amounts are disbursed on behalf of these departments as payments of compensation for land acquired including considerable amount of interest

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:

3 months and 7 years and with fine. 2. It has come to notice that various State Development Authorities, the Housing Boards, Public Works Department, etc., acquire immovable property from the public for the purpose of their developmental activities. Huge amounts are disbursed on behalf of these departments as payments of compensation for land acquired including considerable amount of interest

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:

3 months and 7 years and with fine. 2. It has come to notice that various State Development Authorities, the Housing Boards, Public Works Department, etc., acquire immovable property from the public for the purpose of their developmental activities. Huge amounts are disbursed on behalf of these departments as payments of compensation for land acquired including considerable amount of interest

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:

3 months and 7 years and with fine. 2. It has come to notice that various State Development Authorities, the Housing Boards, Public Works Department, etc., acquire immovable property from the public for the purpose of their developmental activities. Huge amounts are disbursed on behalf of these departments as payments of compensation for land acquired including considerable amount of interest

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

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

THE SECUNDERBAD CLUB ,HYDERABAD vs. ITO WARD -10(2), HYDERABAD

Appeal is dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

house property: 8.4 In this context, it is important to understand the principle of mutuality before adjudicating the issue on hand. It is well settled principle of law that, in order to fulfil the requirement of mutuality, a mutual association has to establish the crucial criteria that there is identity between contributors and participators / recipients to the fund i.e. there

NAVEEN KUMAR MUSINIPALLY,USA vs. ADIT (INT-TAXN)-1, HYDERABAD

In the result, appeal of the Assessee partly allowed

house received by the assessee in pursuance to JDA of the property as deduction u/sec.54F of the Act.\n9. Aggrieved by the order of the learned CIT(A), the assessee is now, in appeal before the Tribunal.\n10. CA, KC Devdas, Learned Counsel for the Assessee referring to the notice issued by the ACIT, [INTL-TAXN

KRISHNA KISHORE REDDY MANYAM ,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(4) , HYDERABAD

In the result, the appeal filed by the assessee is partly allowed\nfor statistical purposes in terms of our aforesaid observations

house, vide a registered sale deed\ndated 23.07.2011 an amount of Rs.90 lac. Apart from that, it was\nobserved by him that the assessee had made payments of Rs.72\nlacs towards the construction/renovation based on an\nunregistered agreement dated 18.04.2008 in respect of the new\nhouse property. Considering the aforesaid facts, the CIT(A)\naccepted the assessee's claim

DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD vs. BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU, YSR DIST., YSR DIST.

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

section 68 of the Act. On appeal, the Ld. CIT (A) after hearing the Ld. AR on few occasions upheld the order of the Ld. AO as he was also of the view that the identity, creditworthiness, genuineness of the transaction have not been established. While arriving at such decision, he relied on the second remand report obtained from

BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU,KADAPA vs. DCIT, CIRCLE-1(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

section 68 of the Act. On appeal, the Ld. CIT (A) after hearing the Ld. AR on few occasions upheld the order of the Ld. AO as he was also of the view that the identity, creditworthiness, genuineness of the transaction have not been established. While arriving at such decision, he relied on the second remand report obtained from

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

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

section 153C of the Act. Neither the statement of Shri Kolla Madhava Reddy nor the Settlement Order of the Settlement Commission nor statement of Kolla Madhav Abhilash, Director can be said to be the incriminating documents / evidence for the purpose of making the addition in the hands of the assessee as the said document or the admission of the liability

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

section 153C of the Act. Neither the statement of Shri Kolla Madhava Reddy nor the Settlement Order of the Settlement Commission nor statement of Kolla Madhav Abhilash, Director can be said to be the incriminating documents / evidence for the purpose of making the addition in the hands of the assessee as the said document or the admission of the liability

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

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

section 153C of the Act. Neither the statement of Shri Kolla Madhava Reddy nor the Settlement Order of the Settlement Commission nor statement of Kolla Madhav Abhilash, Director can be said to be the incriminating documents / evidence for the purpose of making the addition in the hands of the assessee as the said document or the admission of the liability

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

section 153C of the Act. Neither the statement of Shri Kolla Madhava Reddy nor the Settlement Order of the Settlement Commission nor statement of Kolla Madhav Abhilash, Director can be said to be the incriminating documents / evidence for the purpose of making the addition in the hands of the assessee as the said document or the admission of the liability

RAMESH CHANDRA MAJITHIA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

section 153C of the Act. Neither the statement of Shri Kolla Madhava Reddy nor the Settlement Order of the Settlement Commission nor statement of Kolla Madhav Abhilash, Director can be said to be the incriminating documents / evidence for the purpose of making the addition in the hands of the assessee as the said document or the admission of the liability

SULOCHANA NIMMATOORI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G.A N D Shri K. Narasimha Charis.No Ita Nos. Appellant Respondent A.Y 591/Hyd/2022 Shri Ramesh Babu 1 Acit, Central Circle 2017-18 2 619/Hyd/2022 Nimmatoori Hyderabad 2(4) Hyderabad 2018-19 Pan:Acspn1659G 3 700/Hyd/2022 Acit, Central Circle 2(4) Shri Ramesh Babu 2018-19 Hyderabad Nimmatoori Hyderabad Pan:Acspn1659G 4 311/Hyd/2022 Raja Babu Nimmatoori 2013-14 589/Hyd/2022 Hyderabad Acit, Central Circle 5 2016-17 Pan:Acspn1662R 2(4) Hyderabad 6 590/Hyd/2022 2017-18 7 621/Hyd/2022 2018-19 8 701/Hyd/2022 Acit, Central Circle Raja Babu 2018-19 2(4) Hyderabad Nimmatoori Hyderabad Pan:Acspn1662R 9 337/Hyd/2022 Yashoda Nimmatoori Acit, Central Circle 2016-17 593/Hyd/2022 Hyderabad 2(4) Hyderabad 10 2017-18 618/Hyd/2022 Pan:Acspn1657J 11 2018-19 332/Hyd/2022 12 Anudeep Nimmattoori Acit, Central Circle 2016-17 13 475/Hyd/2022 Hyderabad 2(4) Hyderabad 2017-18 476/Hyd/2022 Pan:Ahbpn2081Q 14 2018-19 15 592/Hyd/2022 Sulochana Acit, Central Circle 2017-18 Nimmattoori 2(4) Hyderabad 16 620/Hyd/2022 2018-19 Pan:Acspn1664K 594/Hyd/2022 Manjusha Nimmatoori 17 Acit, Central Circle 2018-19 Hyderabad 2(4) Hyderabad Pan:Acspn1666M िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 13/06/2024 घोषणा की तारीख/Pronouncement: 14/08/2024

property purchased is very old and the same is located nearby the slum area and therefore, based on the guidelines value, provisions of section 56(2)(vii)(b) cannot be invoked. Page 62 of 133 ITA Nos 591 619 700 Ramesh Babu and Others 89. The learned DR, on the other hand, supporting the order of the learned

ANUDEEP NIMMATOORI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G.A N D Shri K. Narasimha Charis.No Ita Nos. Appellant Respondent A.Y 591/Hyd/2022 Shri Ramesh Babu 1 Acit, Central Circle 2017-18 2 619/Hyd/2022 Nimmatoori Hyderabad 2(4) Hyderabad 2018-19 Pan:Acspn1659G 3 700/Hyd/2022 Acit, Central Circle 2(4) Shri Ramesh Babu 2018-19 Hyderabad Nimmatoori Hyderabad Pan:Acspn1659G 4 311/Hyd/2022 Raja Babu Nimmatoori 2013-14 589/Hyd/2022 Hyderabad Acit, Central Circle 5 2016-17 Pan:Acspn1662R 2(4) Hyderabad 6 590/Hyd/2022 2017-18 7 621/Hyd/2022 2018-19 8 701/Hyd/2022 Acit, Central Circle Raja Babu 2018-19 2(4) Hyderabad Nimmatoori Hyderabad Pan:Acspn1662R 9 337/Hyd/2022 Yashoda Nimmatoori Acit, Central Circle 2016-17 593/Hyd/2022 Hyderabad 2(4) Hyderabad 10 2017-18 618/Hyd/2022 Pan:Acspn1657J 11 2018-19 332/Hyd/2022 12 Anudeep Nimmattoori Acit, Central Circle 2016-17 13 475/Hyd/2022 Hyderabad 2(4) Hyderabad 2017-18 476/Hyd/2022 Pan:Ahbpn2081Q 14 2018-19 15 592/Hyd/2022 Sulochana Acit, Central Circle 2017-18 Nimmattoori 2(4) Hyderabad 16 620/Hyd/2022 2018-19 Pan:Acspn1664K 594/Hyd/2022 Manjusha Nimmatoori 17 Acit, Central Circle 2018-19 Hyderabad 2(4) Hyderabad Pan:Acspn1666M िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 13/06/2024 घोषणा की तारीख/Pronouncement: 14/08/2024

property purchased is very old and the same is located nearby the slum area and therefore, based on the guidelines value, provisions of section 56(2)(vii)(b) cannot be invoked. Page 62 of 133 ITA Nos 591 619 700 Ramesh Babu and Others 89. The learned DR, on the other hand, supporting the order of the learned