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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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:

32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain the rule of consistency, we follow the earlier decision

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

32(1)(iia) of the Act, no corresponding amendment is made\nin section 32AC of the Act and therefore, the intention of the\nLegislature is clear that the benefit of section 32AC(1) is not\navailable to a company engaged in the business of generation of\npower. To maintain the rule of consistency, we follow the earlier\ndecision

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

In the result, assessee's appeals for the A

32(1)(iia) of the Act, no corresponding amendment is made\nin section 32AC of the Act and therefore, the intention of the\nLegislature is clear that the benefit of section 32AC(1) is not\navailable to a company engaged in the business of generation of\npower. To maintain the rule of consistency, we follow the earlier\ndecision

JOSEPH KIRAN KUMAR REDDY BASANI,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Manjunatha G. Hon’Ble & Shri K. Narasimha Chary Hon’Bleassessment Year: 2015-16 Vs. The Deputy Commissioner Of Joseph Kiran Kumar Reddy Income Tax, Basani, Circle 5(1), C/O. Pary & Co., Chartered Hyderabad. Accountants, No.6, 2Nd Floor, 8-2-703/Vj/6, Vijay Villa, Road No.12, Banjara Hills, Hyderabad – 500034, Telangana. Pan : Agcpb8082B. (Appellant) (Respondent) Assessee By: Shri Vamsi Krishna Reddy, C.A. Revenue By: Shri Karthik Manickam, Sr.Ar. Date Of Hearing: 29.10.2024 Date Of Pronouncement: 29.10.2024

32,000/- and computed long term capital gain after deducting indexed cost of acquisition of Rs. 2,90,010/- and claimed exemption under Section 54 of the Income Tax Act, 1961 for Rs. 76,83,990/- for purchase of another residential house property

DCIT., CIRCLE-8(1), HYDERABAD vs. DBS TECHNOLOGY SERVICES INDIA PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Deputy Commissioner Of Vs. M/S. Dbs Technology Income Tax, Services India Private Circle – 8(1), Limited, Hyderabad. Hyderabad. Pan : Aafcd5584N (Appellant) (Respondent) C.O.No.2/Hyd/2023 Assessment Year 2019-20 Dbs Technology Services India Vs. Deputy Commissioner Of Private Limited, Income Tax, Circle – 8(1), Hyderabad. Hyderabad. Pan : Aafcd5584N (Cross Objector / (Appellant/Revenue) Respondent) Assessee By: Sri M. P. Lohia, C.A. Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 11.07.2023 Date Of Pronouncement: 21.07.2023 आदेश / O R D E R Per Laliet Kumar, Jm: The Appeal & Cross-Objection Filed By The Revenue For A.Y. 2019-20 Arise From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi

house property and does not have any brought forward loss 3[or loss to be carried forward] under the head; or (iii) xxxxx 4[(I) has assets (including financial interest in any entity) located outside India; (IA) has signing authority in any account located outside India; (IB) has income from any source outside India; (IC) has income to be apportioned

GONUGUNTLA NIRMALA DEVI,ANANTAPUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, ANANTAPUR, ANANTAPUR

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

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

house property at Rs1,11,61,147/- and net income at Rs. 66,36,216/- as against the income shown at Rs.17,09,114/-. The AO has also added an amount of Rs. 54,54,000/- as unexplained investment under section 69C of the Act. The AO has further added an amount of Rs. 32

SURENDER KUMAR BHOJWANI,HYDERABAD vs. ITO, INTL. TAXTION -1, HYDERABAD

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

house” as provided in section 54F of the Act, therefore, no income was liable to be brought to tax in his hands under the head “Capital gains”. Apart from that, the Ld. AR submitted that though the claim of deduction u/s 54F of the Act was not raised by the assessee in his original return of income or the revised

NITIN BHATIA,HYDERABAD vs. ITO., WARD-12(1), HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1472/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Shri Nitin Bhatia Vs. Income Tax Officer Hyderabad Ward 12 (1) Pan:Akqpb1898R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Y.V Bhanu Narayan Rao राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 16/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

property (“Original Residential House”) vide registered sale deed dated 14.12.2017 for a total consideration of Rs.3,70,00,000/-. The long-term capital gain on the said transfer was computed at Rs.1,33,83,234/-, out of which the assessee’s share at 50% worked out to Rs.66,91,617/-. The assessee claimed deduction of the entire long term capital

PATNA BAKHTIYARPUR TOLLWAY LIMITED,HYDERABAD vs. ACIT., CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleassessment Year – 2017-18 Patna Bakhtiyarpur Tollway Vs. Acit Circle-16(2) Limited Hyderabad Hyderabad Pan : Aafcp9577K (Appellant) (Respondent) Assessee By: Shri S.Rama Rao, Ar Revenue By: Ms.K.Haritha, Cit-Dr Date Of Hearing: 05.12.2024 31.12.2024 Date Of Pronouncement:

property. 14. We have heard the rival contentions and gone through the material available on record. The claim of depreciation under the 26 scheme of income tax as provided under section 32 of the Act which is as under : Depreciation. 32. (1) In respect of depreciation of— (i) buildings, machinery, plant or furniture, being tangible assets; (ii) know-how, patents

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3),, HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

32,144 sq.ft out of the reaming built up area. During the course of assessment proceedings, the Assessing Officer observed that by entering into the joint development agreement with the developer, the assessee has commercially exploited the property by carrying out business activities and has also undertaken inventory risk, credit risk and market risk. Therefore, opined that property received

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. TARA CHAND BOPPANA, HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

32,144 sq.ft out of the reaming built up area. During the course of assessment proceedings, the Assessing Officer observed that by entering into the joint development agreement with the developer, the assessee has commercially exploited the property by carrying out business activities and has also undertaken inventory risk, credit risk and market risk. Therefore, opined that property received

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. SARAT GOPAL BOPPANA, HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

32,144 sq.ft out of the reaming built up area. During the course of assessment proceedings, the Assessing Officer observed that by entering into the joint development agreement with the developer, the assessee has commercially exploited the property by carrying out business activities and has also undertaken inventory risk, credit risk and market risk. Therefore, opined that property received

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. JHANSI RANI BOPPANA, HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

32,144 sq.ft out of the reaming built up area. During the course of assessment proceedings, the Assessing Officer observed that by entering into the joint development agreement with the developer, the assessee has commercially exploited the property by carrying out business activities and has also undertaken inventory risk, credit risk and market risk. Therefore, opined that property received

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. KAVYA BOPPANA, HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

32,144 sq.ft out of the reaming built up area. During the course of assessment proceedings, the Assessing Officer observed that by entering into the joint development agreement with the developer, the assessee has commercially exploited the property by carrying out business activities and has also undertaken inventory risk, credit risk and market risk. Therefore, opined that property received

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

32,144 sq.ft out of the reaming built up area. During the course of assessment proceedings, the Assessing Officer observed that by entering into the joint development agreement with the developer, the assessee has commercially exploited the property by carrying out business activities and has also undertaken inventory risk, credit risk and market risk. Therefore, opined that property received

KAVYA BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

32,144 sq.ft out of the reaming built up area. During the course of assessment proceedings, the Assessing Officer observed that by entering into the joint development agreement with the developer, the assessee has commercially exploited the property by carrying out business activities and has also undertaken inventory risk, credit risk and market risk. Therefore, opined that property received