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 :

14A of the Act. Accordingly, ground No.1 raised by the Revenue is dismissed. 17 ITA.No.1187/Hyd/2018 GROUNDS 2 TO 4 11. Ground nos. 2 to 4 raised by the Revenue are inter- connected and are with respect to the shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

2)(iiihk) and (iiihl) of the Act. (para\n16) We are in agreement with such observations and findings of the\nCoordinate Bench of the Tribunal and while respectfully following the\nsame, we hold that inasmuch as the assessee satisfied the conditions\nof section 80G of the Act, the assessee is entitled to claim deduction\nunder section

BALA REDDY GOPU, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD

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

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

14A as per the direction in ITA No. 455/Hyd/2017 (supra). 11. As regards ground Nos. 2 to 5 regarding addition of Rs. 7,68,03,155/- u/s 68 of the Act, the assessee is deriving income from salary, income from house property, income from other sources etc., and the assessee filed return of income for asst. Year 2011-12 admitting

UNION BANK OF INDIA (ERSTWHILE-ANDHRA BANK),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

68. Aggrieved by the Ld.CIT(A) order, the assessee is now in appeal before the Tribunal. 69. The Ld. Counsel for the assessee submitted that the Ld.CIT(A) is erred in sustaining the additions made by the Assessing Officer towards disallowance of penalty paid to RBI for violation of section 46(4) of the Banking Regulation

ANANDA PRASAD VENIGALA,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1384/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Ananda Prasad Venigala, Dy. Commissioner Of Income Tax, Vs. Circle-1(1), Hyderabad. Hyderabad. Pan:Aewpp1096B (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By:: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 31/07/2025 घोर्णध की तधरीख/Pronouncement: 06/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Ananda Prasad Venigala (“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 18.11.2024 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

68 of the Act of Rs.1,05,50,000/-. 6. As far as the disallowance under Section 14A of the Act is concerned, the Ld. AR first submitted that the disallowance is unjustified because the Ld. AO failed to record proper satisfaction, as required under Section 14A(2

CHINTALAPATI HOLDINGS PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

68,76,378/-. 7. On this aspect, observation of the learned Assessing Officer was that just two months prior to the selling of shares by the assessee at Rs. 10/- per share, M/s. Ind-Barath Power Infra Ltd., raised money from private equity funds by allotting shares at a premium of Rs. 187.58 in October, 2009. Learned Assessing Officer also

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

68,76,378/-. 7. On this aspect, observation of the learned Assessing Officer was that just two months prior to the selling of shares by the assessee at Rs. 10/- per share, M/s. Ind-Barath Power Infra Ltd., raised money from private equity funds by allotting shares at a premium of Rs. 187.58 in October, 2009. Learned Assessing Officer also

CHINTALAPATI HOLDINGS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

68,76,378/-. 7. On this aspect, observation of the learned Assessing Officer was that just two months prior to the selling of shares by the assessee at Rs. 10/- per share, M/s. Ind-Barath Power Infra Ltd., raised money from private equity funds by allotting shares at a premium of Rs. 187.58 in October, 2009. Learned Assessing Officer also

LYCOS INTERNET LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

2 to 4 are regarding disallowance made by the Assessing Officer u/s 14A was deleted by the learned CIT (A). The learned DR has submitted that the learned CIT (A) has deleted the addition on the ground that no exempt income was earned by the assessee in respect of the investment made in the shares of subsidiary/group entities

UNION BANK OF INDIA (ERSTWHILE- ANDHRA BANK),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

14A since the investments are stock in trade. 3.2. Without prejudice to the above, the Commissioner of Income Tax (Appeals) failed to appreciate the fact that the Ld. Assessing Officer erred in invoking Rule 8D without recording a finding as to how the assessee incurred expenditure to earn tax free income. 3.3. The Commissioner of Income Tax (Appeals) failed

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD vs. ANDHRA BANK , HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

14A since the investments are stock in trade. 3.2. Without prejudice to the above, the Commissioner of Income Tax (Appeals) failed to appreciate the fact that the Ld. Assessing Officer erred in invoking Rule 8D without recording a finding as to how the assessee incurred expenditure to earn tax free income. 3.3. The Commissioner of Income Tax (Appeals) failed

UNION BANK OF INDIA,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

14A since the investments are stock in trade. 3.2. Without prejudice to the above, the Commissioner of Income Tax (Appeals) failed to appreciate the fact that the Ld. Assessing Officer erred in invoking Rule 8D without recording a finding as to how the assessee incurred expenditure to earn tax free income. 3.3. The Commissioner of Income Tax (Appeals) failed

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD vs. ANDHRA BANK , HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

14A since the investments are stock in trade. 3.2. Without prejudice to the above, the Commissioner of Income Tax (Appeals) failed to appreciate the fact that the Ld. Assessing Officer erred in invoking Rule 8D without recording a finding as to how the assessee incurred expenditure to earn tax free income. 3.3. The Commissioner of Income Tax (Appeals) failed

UNION BANK OF INDIA,HYDERABAD vs. DY. COMMISSISONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

2 of 59 ITA Nos 1018 and 1230 of 2017 Andhra Bank 3.1 The Commissioner of Income tax (Appeals) ought to have seen that under Section 36(1)(viia) of the Act, amount not exceeding seven and one-half percent of the total income and an amount not exceeding ten per cent of the aggregate average advances made

DY. COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), HYDERABAD vs. UNION BANK OF INDIA, HYDERABAD

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

2 of 59 ITA Nos 1018 and 1230 of 2017 Andhra Bank 3.1 The Commissioner of Income tax (Appeals) ought to have seen that under Section 36(1)(viia) of the Act, amount not exceeding seven and one-half percent of the total income and an amount not exceeding ten per cent of the aggregate average advances made

KRISHNA CONSTRUCTIONS,NIRMAL vs. INCOME TAX OFFICER, WARD-1, NIRMAL

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1330/Hyd/2025 Assessment Year 2017-2018 Krishna Constructions The Income Tax Officer, Nirmal. Telangana. Ward-1, Vs. Pin – 504 106. Nirmal – 504 106. Pan Aapfk1280K Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri D Prabhakar Reddy, Advocate राज" व "ारा/Revenue By : Dr. Sachin Kumar,Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10.03.2026 घोषणा की तारीख/Pronouncement: 08.04.2026 आदेश/Order Per Vijay Pal Rao:

14A and 68 of the Act. By making an addition u/s.69 of the Act, the AO has clearly exceeded the jurisdiction vested in him and travelled beyond the scope of limited scrutiny. 96. For this reason, we are unable to subscribe to the reasoning adopted by the Ld. CIT(A) that since the asset in question was included

BHASKAR TRANSPORT PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, HYDERABAD

In the result, all the appeals of the assessee are allowed

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

2) and 142(1) of the Income Tax Act [Act] were issued to the assessee- company. The assessee-company had duly complied with the said notices. The assessment proceedings u/s. 143(3) were completed on 06-03- 2014 by making the addition as under: A. Disallowance of interest u/s 14A: i. The Assessing Officer while completing the assessment

BHASKAR TRANSPORT PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, HYDERABAD

In the result, all the appeals of the assessee are allowed

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

2) and 142(1) of the Income Tax Act [Act] were issued to the assessee- company. The assessee-company had duly complied with the said notices. The assessment proceedings u/s. 143(3) were completed on 06-03- 2014 by making the addition as under: A. Disallowance of interest u/s 14A: i. The Assessing Officer while completing the assessment

BHASKAR TRANSPORT PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(3), HYDERABAD

In the result, all the appeals of the assessee are allowed

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

2) and 142(1) of the Income Tax Act [Act] were issued to the assessee- company. The assessee-company had duly complied with the said notices. The assessment proceedings u/s. 143(3) were completed on 06-03- 2014 by making the addition as under: A. Disallowance of interest u/s 14A: i. The Assessing Officer while completing the assessment