IN THE HIGH COURT FOR THE STATE OF TELANGANA ::

HYDERABAD * * *

INCOME TAX TRIBUNAL APPEAL Nos.19, 20, 21, 24, 25, 27, 28, 38, 42, 44, 56, 79, 80, 81, 226, 229, 230, 232, 235, 237 of 2019 AND

42 of 2020 Between:

The Commissioner of Income-tax (Exemptions), Hyderabad.

Appellant VERSUS Hyderabad Metropolitan Development Authority, (formerly known as HUDA), 1-8-23, Paigah Palace, Opp: Rasoolpura Police Station, Begumpet, Hyderabad.

Respondent COMMON JUDGMENT PRONOUNCED ON: 06.02.2026 THE HON’BLE SRI JUSTICE P.SAM KOSHY AND THE HON’BLE SRI JUSTICE SUDDALA CHALAPATHI RAO

1. Whether Reporters of Local newspapers may be allowed to see the Judgments? : Yes

2. Whether the copies of judgment may be marked to Law Reporters/Journals? : Yes

3. Whether His Lordship wishes to see the fair copy of the Judgment? : Yes _______________ P.SAM KOSHY, J * THE HON’BLE SRI JUSTICE P.SAM KOSHY AND THE HON’BLE SRI JUSTICE SUDDALA CHALAPATHI RAO + INCOME TAX TRIBUNAL APPEAL Nos.19, 20, 21, 24, 25, 27, 28, 38, 42, 44, 56, 79, 80, 81, 226, 229, 230, 232, 235, 237 of 2019 AND

42 of 2020 % 06.02.2026 # Between:

The Commissioner of Income-tax (Exemptions), Hyderabad.

Appellant VERSUS Hyderabad Metropolitan Development Authority, (formerly known as HUDA), 1-8-23, Paigah Palace, Opp: Rasoolpura Police Station, Begumpet, Hyderabad.

Respondent ! Counsel for appellant : Mr. Vijhay K. Punna, learned Senior Standing Counsel for Income Tax Department.

^Counsel for respondent : Mr. A.V. Krishna Koundinya, learned Senior Counsel appearing on behalf of Mr. A.V.A.Siva Kartikeya.

GIST:

> HEAD NOTE:

? Cases referred IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD THE HON’BLE SRI JUSTICE P.SAM KOSHY AND THE HON’BLE SRI JUSTICE SUDDALA CHALAPATHI RAO INCOME TAX TRIBUNAL APPEAL Nos.19, 20, 21, 24, 25, 27, 28, 38, 42, 44, 56, 79, 80, 81, 226, 229, 230, 232, 235, 237 of 2019 AND

42 of 2020 DATE: 06.02.2026 Between :

The Commissioner of Income-tax (Exemptions), Hyderabad. …Appellant AND Hyderabad Metropolitan Development Authority, (formerly known as HUDA), 1-8-23, Paigah Palace, Opp: Rasoolpura Police Station, Begumpet, Hyderabad.

…Respondent

COMMON JUDGMENT:

(per the Hon’ble Sri Justice P.Sam Koshy)

Since the lis involved in this batch of appeals is between the same parties, and the contentions put forth on either side also being the same, they were heard together and are decided by this Common Judgment.

2. Heard Mr. Vijhay K. Punna, learned Senior Standing Counsel for Income Tax Department appearing on behalf of the appellant; and Mr. A.V. Krishna Koundinya, learned Senior Counsel appearing on behalf of Mr. A.V.A.Siva Kartikeya, learned counsel for the respondent.

3. These are 21 appeals preferred by the Revenue pertaining to different assessment years starting from 2003-04 to 2013-14. The assessment year involved in these 21 appeals for ready reference is mentioned below in the tabular form, viz., 4. The whole dispute revolving around the present batch of appeals pertains to the entitlement of exemption under Section 12A of the Income Tax Act, 1961 (for short the ‘Act of 1961’) so far as the respondent / assessee establishment is concerned.

5. The assessee in the instant case is Hyderabad Metropolitan Development Authority, which was earlier known as Hyderabad Urban Development Authority. The assessee is an establishment originally established under Section 3 of the Andhra Pradesh Areas Urban Development Act, 1975 (for short the ‘Act of 1975’). The assessee otherwise meets all the requirements and is also considered to be a local authority under the said Act of 1975. It was only under the Hyderabad Metropolitan Development Authorities Act, 2008 (for short the ‘Act of 2008’) the Hyderabad Urban Development Authority got merged into Hyderabad Metropolitan Development Authority (for short ‘HMDA’).

6. The assessee is one which has been established in order to provide for better planning, coordination, supervision, promotion and securing a planned development for the city of Hyderabad and aime