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:

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 on excess compensation as per the Land Acquisition Act. The interest payment made under the Land Acquisition Act are covered

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:

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 on excess compensation as per the Land Acquisition Act. The interest payment made under the Land Acquisition Act are covered

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:

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 on excess compensation as per the Land Acquisition Act. The interest payment made under the Land Acquisition Act are covered

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:

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 on excess compensation as per the Land Acquisition Act. The interest payment made under the Land Acquisition Act are covered

EXEL RUBBER PRIVATE LIMITED,K.V.RANGAREDDY vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

66,36,659 2,51,76,51,3151240661 ए. टी. वी. कमार, भारा से. KA TV. KUMAR. IR S. 12 6/1/2025 As stated earlier, these unaccounted cash transactions as recorded above contain details of cash generated from sale of scrap, purchase adjustments/accommodations, sale of raw materials, sale of immovable property, interest received on loans advanced, repayment of such loans advanced

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

66,36,659 2,51,76,51,3151240661 Arivkumar 06/01/22 ए. टी. वी. कमार, भारा से. KA TV. KUMAR. IR S. 8. 6/1/2025 As stated earlier, these unaccounted cash transactions as recorded above contain details of cash generated from sale of scrap, purchase adjustments/accommodations, sale of raw materials, sale of immovable property, interest received on loans advanced, repayment of such

MAHESWARI MINING & ENERGY PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri K. Narasimha Charyassessment Years: 2016-17 Maheswari Mining & Vs. Asst. Commissioner Of Energy Pvt. Ltd., Income-Tax, Hyderabad. Circle – 16(2), Hyderabad. Pan – Aagcm0805N (Appellant) (Respondent) Assessee By: S/Shri Y. Ratnamkar& B. Satyanarayana Murthy Revenue By: Shri Y.V.S.T. Sai Date Of Hearing: 21/04/2022 Date Of Pronouncement: /04/2022

properties. Such aspect has been taken care by the provision itself. The executive is required only to supplement the provision by specifying the backward areas by way of notification. Hence, the decision in ITC, Bhadrachalam (supra), has, therefore, no application to the facts of the case. 28. Next case on which the Revenue places heavy reliance is the case

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

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

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

property held under trust, wholly or in part has been applied, other than for the objects of the trust, is totally misconceived and not based on any evidences found during the course of search. 26. Further, unquestionably the onus for proving the existence of factors calling for the cancellation of a trust or institution is on the Department rather than

NETENRICH TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

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

Bench: SHRI MANJUNATHA G. (Accountant Member), SHRI K.NARASIMHA CHARY (Judicial Member)

property held under trust, wholly or in part has been applied, other than for the objects of the trust, is totally misconceived and not based on any evidences found during the course of search. 26. Further, unquestionably the onus for proving the existence of factors calling for the cancellation of a trust or institution is on the Department rather than

ACIT, CENTRAL CIRCLE-3(1), HYDERABAD vs. SRI CHAITANYA EDUCATIONAL COMMITTE, VIJAYAWADA

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

house property', 'profits and gains of business or profession' and capital gains and income from other sources. In the instant case considering the activity of the assessee the other income which has to be taxed at normal rates has to be computed under the head 'profits and gains of business or profession' as the activity of the assessee is akin

RACHIT V SHAH,HYDERABAD vs. ITO, WARD-7(3), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

house property to his father, Sri Vijay kumar shah by way of gift settlement deed in doc.No.107 of 2014 executed on 27-10-2014. Immediately after this gift settlement i.e, within a gap of 7 days, the assessee sold one land property jointly held with his mother in Survey Nos.114 and115 situated at Gaganpahad village, Rajendernagar· Mandal, Rangareddy District

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

1. “The order of the learned Authorities below in so far as it is against the Appellant is opposed to law, equity, weight of evidence, probabilities and the facts and circumstances in the Appellant's case. 2. The Appellant denies himself liable to assessed on a total income of Rs.7,73,80,535/-, as against the returned income of Rs.5

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

1 in pursuance of the impugned notice issued by him against the appellant. Under these circumstances we do not propose to deal with the point of law sought to be raised by Mr. Nambiar. We would, however, like to add one direction in fairness to the appellants. The proceedings taken against both the appellants should continue and should be dealt

INCOME TAX OFFICER (INTERNATIONAL TAXATION)-1, HYDERABAD vs. ARUNA GULLAPALLI, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Income Tax Officer, Vs. Aruna Gullapalli, (International Taxation) – 1, Hyderabad. Hyderabad. Pan No.Bfhpg9489L. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Kumar Adithya Date Of Hearing: 23.01.2023 Date Of Pronouncement: 31.01.2023

section 54(1), you are exempt". 7 12.6 Further, in Mukesh G. Desai(HUF) vs. ITO(2009) 312 ITR(AT) (302)(MUM) it was held: "Where the assessee enters into an agreement for investment in purchase of a flat, but later the agreement gets cancelled and the assessee gets refund and utilizes the same for purchase of another property within

KAMLESH RANKA,HYDERABAD vs. INCOME TAX OFFICER, INTL. TAXATION-II, , HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri A. Mohan Alankamonyassessment Year: 2012-13 Kamlesh Ranka, Vs. Income Tax Officer, Hyderabad. Intl. Taxation-Ii, Pan: Acbpr 3953 N Hyderabad. (Appellant) (Respondent) Assessee By: Sri D. Satyanarayana Revenue By: Sri Nilanjan Dey Date Of Hearing: 22/07/2019 Date Of Pronouncement: 12/09/2019

66,54,115 ÷ 100 X 785) = Rs. 51,34, 803 = Rs. 23,65,197 Less deduction U/s. 54 = Rs. 23,65,197 LTCG = NIL______ (Investment in House Property U/s. 54 of the Act Rs. 1,03,36,000) 5. Thereafter, the Ld. AO after examining the case of the assessee computed the LTCG of the assessee by adopting the assessee

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

1,14,809/- claimed by the assessee was also disallowed. 5.4 As per the information available, the assessee had entered into a property transaction to the tune of Rs. 54,54,000/- on 24.11.2016. As the assessee did not offer any explanation about the said property transaction and has categorically denied having entered into any property transaction vide her letter

GOWRI SHANKAR GUPTA,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(3), HYDERABAD

1. On the facts and in the circumstances of the case the order passed by the National Faceless Appeals Centre(hereinafter referred to as NFAC) is erroneous both on facts and in law. 2. The NFAC erred in confirming the addition made by the AO amounting to Rs.11,02,500/- on account of rental receipt from M/s leadspace under

ANANTAPUR DISTRICT CO-OPERATIVE STAFF CO-OPERATIVE SOCIETY LIMITED,ANANTAPUR vs. ITO., WARD-1, ANANTAPUR

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

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdiaआ.आआआ.आआ /Ita No.1142/Hyd/2024 (आआआआआआआआ आआआआ/Assessment Year:2016-17) M/S. Anantapur District Co- Income Tax Officer, Vs. Ward-1, Anantapur. Operative Staff Co-Operative Society Limited, Anantapur. Pan:Aaeaa0133B (Appellant) (Respondent) आआआआआआआआआआ आआआआआआ/Assessee Dr. D. Harish Chandra Rama, Ca By: आआआआआआ आआआआआआ/Revenue By: Dr. Sachin Kumar, Sr-Dr आआआआआआ आआ आआआआआ/Date Of 24/02/2025 Hearing: आआआआआ आआ 04/03/2025 आआआआआ/Pronouncement: आआआआ/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Anantapur District Co-Operative Staff Co-Operative Society Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 05.09.2024 For The A.Y. 2016-17. 2. The Facts Of The Case Are That The Assessee Is An Association Of Persons (“Aop”), Not Filed Any Return Of Income (“Roi”) U/S.139 Of The Income Tax Act, 1961 ('The Act'). From The Information

66 (Andhra Pradesh), the Hon’ble High Court reached a conclusion that if the investment is made in fixed deposits in nationalised banks from out of the own funds of the assessee, the interest derived from such investment would be from the activities listed in clause (i) to (vii) of section 80P(2)(a) of the Act and would