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

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

v. Dilip Kumar & Co. and Ors: (2018) 9 SCC 1 to submit that it is now settled beyond doubt that taxing statutes are subject to the rule of strict interpretation, leaving no room for any intendment; and the benefit of ambiguity in case of an exemption notification or an exemption clause must go in favour of the revenue, as exemptions

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

v. Dilip Kumar & Co. and Ors: (2018) 9 SCC 1 to submit that it is now settled beyond doubt that taxing statutes are subject to the rule of strict interpretation, leaving no room for any intendment; and the benefit of ambiguity in case of an exemption notification or an exemption clause must go in favour of the revenue, as exemptions

ACIT., CIRCLE-5(1), HYDERABAD vs. SANJAY CHOWDARY GADDIPATI, HYDERABAD

1) of the Act does not lay down\nany anterior/opening time limit or “one year before” window, i.e.\nany specific period prior to the transfer of the capital asset for the\npurchase of a residential plot/land on which the new residential\nhouse is to be constructed; nor circumscribes any such time limit\nfor starting the construction of the said

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. CACHE PROPERTIES PRIVATE LIMITED , HYDERABAD

In the result, the Revenue’s appeal is dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

1, Hyderabad is erroneous both on facts and in law. 2. The Ld. CIT (A) ought to have allowed the appeal in full. 3. The Ld. CIT (A) erred in confirming the addition of Rs. 12,82,87,569 made by the AO by treating the income from house property as income from business. 4. The Ld. CIT (A) ought

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:

v) any plant or machinery, the whole of the actual cost of which is allowed as deduction (whether by way of depreciation or otherwise) in computing the income chargeable under the head "Profits and gains of business or profession" of any previous year.] [32AD. Investment in new plant or machinery in notified backward areas in certain States.-- (1) Where

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:

v) any plant or machinery, the whole of the actual cost of which is allowed as deduction (whether by way of depreciation or otherwise) in computing the income chargeable under the head "Profits and gains of business or profession" of any previous year.] [32AD. Investment in new plant or machinery in notified backward areas in certain States.-- (1) Where

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:

v) any plant or machinery, the whole of the actual cost of which is allowed as deduction (whether by way of depreciation or otherwise) in computing the income chargeable under the head "Profits and gains of business or profession" of any previous year.] [32AD. Investment in new plant or machinery in notified backward areas in certain States.-- (1) Where

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:

v) any plant or machinery, the whole of the actual cost of which is allowed as deduction (whether by way of depreciation or otherwise) in computing the income chargeable under the head "Profits and gains of business or profession" of any previous year.] [32AD. Investment in new plant or machinery in notified backward areas in certain States.-- (1) Where

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

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

section 132 of the income tax Act 1961/37Aof-the WT Act-1957 in the case of (A) above to search the place of mentioned at (B) above and duly signed and sealed by the Pr. Director of Income tax (Inv.), Hyderabad to Shri Satendra Sharma (Security incharge) who was present in the said place at the time and after-reading

CACHE PROPERTIES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

1, Hyderabad is erroneous both on facts and in law. 2. The Ld. CIT (A) ought to have allowed the appeal in full. 3. The Ld. CIT (A) erred in confirming the addition of Rs. 12,82,87,569 made by the AO by treating the income from house property as income from business. 4. The Ld. CIT (A) ought

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

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

house keeping latitur charges 20 to 26 april13 1,000 Staff Welfare 27-04-2011 Cach tash to be received hom gvg-giftemirso 9,750 Repars & Maintenance-Factory 27-04-2013 Cash water curing daily labour 20 to 26 april33 500 Commissions & Other Miscellaneous Business Expennis 27-04-2013 Cash civil work labour charges 20 to 26 april13

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

housing project subsequent to assessment framed by the AO by filing an application u/s. 264 before the CIT and made the claim of deduction u/s. 80IB(10). The CIT, therefore rejected the revision application holding that since assessee had not made a claim under section 80IB(10) in the return of income, by virtue of section 80IA(5), the claim

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

housing project subsequent to assessment framed by the AO by filing an application u/s. 264 before the CIT and made the claim of deduction u/s. 80IB(10). The CIT, therefore rejected the revision application holding that since assessee had not made a claim under section 80IB(10) in the return of income, by virtue of section 80IA(5), the claim

INCOME TAX OFFICER, WARD-2(1), HYDERABAD vs. NARASIMHA REDDY DUTHALA, HYDERABAD

Bench: Shri Manjunatha G & Shri Ravish Sood

V – Conclusion: 42. In the case of the assessee, the following conclusions are drawn : A. The assessee, as per his own I.T. R. furnished for AY. 2021-22, claimed that he owned more than one residential house as on March 31, 2021. However, during the course of assessment proceedings, the assessee claims that one of the houses is not owned

ACIT., EXEMPTIONS CIRCLE-1(1), HYDERABAD vs. PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025

9 …….. 24. We do not intend to burden this order with a plethora of authorities on the construction of a Section, but since a point of grammar is also involved in the interpretation of the provision, we think it fit and appropriate to briefly refer to a few rules of interpretation laid down in some of the decided cases

SRIDHAR REDDY BAYAPU,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

Bench: Us:

9. 19/11/2015 416 10,24,645 10. 18/04/2016 547 13,25,000 11. 14/10/2016 931 8,00,000 12. 10/01/2017 1031 1,80,150 13. 10/01/2017 1030 5,00,000 14. 20/01/2017 1041 4,40,000 15. 08/05/2017 138 3,45,000 16. 08/05/2017 039 3,00,000 17 08/05/2017 1182 1,45,429 Total 1

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

house. Once an assessee falls within the ambit of a beneficial provision , then the said provision should be liberally interpreted. The Supreme Court in the case of CCE V.Favourite Industries (2012) 16 GSTR 184(SC); (2012) 7 SCC 153 has succinctly observed thus (page 191 of 16 GSTR)" At page-575 "It is now a well-established principle

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 and if such investment is made within the period stipulated therein, then Section 54F(4) is not at all attracted and therefore, the contention that the assessee has not deposited the amount in the Bank account as stipulated and therefore, he is not entitled to the benefit even though he has invested the money in construction is also