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2026 Supreme(Telangana) 111

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
P.SAM KOSHY, SUDDALA CHALAPATHI RAO
Nuziveedu Seeds Ltd. – Appellant
Versus
Chief Commissioner Of Income-Tax – Respondent


Advocates Appeared:
For the Appellant : Sri. S. Ravi, Learned Senior In Both The Appeals Counsel Representing M/s. Ckr Associates
For the Respondent: Sri. K. Sudhakar Reddy, Learned Senior Counsel For Income Tax Department

JUDGMENT :

Suddala Chalapathi Rao, J.

1. The instant appeals have been filed challenging the orders passed by the Income Tax Appellate Tribunal, Hyderabad Bench-A (for short ‘the learned ITAT’) in ITA.No.1463/HYD/2017 and ITA.No.1464/HYD/2017, both dt.31.05.2022 relating to the assessment years 2012-13 and 2013-14, respectively.

2. As both appeals emanate from proceedings concerning the same assessee and raise common issues, though pertaining to two different assessment years, they are analogously heard and are being disposed of by this common judgment.

THE BRIEF FACTS:

3. The appellant-company is a public limited company engaged in the research, production, and sale of hybrid seeds and open-pollinated seed varieties of various crops. The appellant filed its return for the assessment years 2012-13 admitting a total income of Rs.17.778 crores under the normal provisions and book profit of Rs.14.74 crores under Section 115JB, and for the assessment year 2013-14, it admitted a total income of Rs.43.64 crores under the normal provisions and book profit of Rs.40.92 crores under Section 115JB.

4. The Assessing Authority passed separate assessment orders on 30.03.2015 for both the assessment ye

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