PVV INFRA LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B‘ Bench, Hyderabad �ी रिवश सूद,�ाियक सद� एवं �ी मधुसूदन साविड़या लेखा सद� सम� | Before Shri Ravish Sood, Judicial Member A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No. 1262/Hyd/2025 (िनधा�रण वष�/Assessment Year: 2020-21) PVV Infra Limited Vs. Dy. CIT Hyderabad Circle 5(1) PAN: AAACT8344D Hyderabad (Appellant) (Respondent) िनधा�रती �ारा/Assessee by: Advocate M Vani राज� व �ारा/Revenue by:: Smt.Uppaluri Meena,Sr. AR सुनवाई की तारीख/Date of hearing: 10/06/2026 घोषणा की तारीख/Pronouncement: 17/06/2026 आदेश/ORDER Per Madhusudan Sawdia, A.M.:

This appeal is filed by M/s. PVV Infra Ltd (“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 09.06.2025 for the A.Y.2020-21. 2. The assessee has raised the following grounds of appeal:

absence of satisfactory explanation, the Ld. AO made an addition of Rs.2,93,65,103/- on account of such difference in purchases and completed the assessment under section 143(3) r.w.s 144B of the Act on 03.09.2022 assessing the total income of the assessee at Rs.3,09,39,063/-. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). However, in the absence of sufficient supporting evidence, the Ld. CIT(A) sustained the addition made by the Ld. AO and dismissed the appeal of the assessee. 5. Aggrieved by the order of the Ld. CIT (A), the assessee is now in appeal before the Tribunal. The Learned Authorized Representative (“Ld. AR”) submitted that the solitary issue arising from the grounds of appeal of the assessee relates to the addition of Rs.2,93,65,103/- made by the Ld. A.O on account of the difference in purchases between the books of account of the assessee and the GST returns. The Ld. AR filed certain additional evidences in the form of ledger accounts, purchase register and credit note register and submitted that these documents are crucial for adjudication of the issue involved and go to the root of the matter. Accordingly, he prayed for admission of the additional evidences. Inviting our attention to the ledger account of CTIL E Housing Private Limited in the books of the assessee placed at page nos. 1 & 2 of the additional evidence paper book, the Ld. AR submitted that the assessee had received a debit note from the said party dated 31.12.2019 for a sum of Rs.2,93,65,103/-. However, due to an inadvertent accounting error, instead of debiting the said amount to the purchase account, the same was credited to the

sales account of the assessee. It was submitted that the impugned addition has arisen only due to such accounting mistake and there was no suppression of purchases or inflation of expenditure. Accordingly, the Ld. AR prayed that the addition made by the lower authorities be deleted. 6. Per contra, the Learned Departmental Representative (“Ld. DR”) strongly objected to the admission of the additional evidences and submitted that the assessee had failed to substantiate its claim before the lower authorities despite sufficient opportunities having been granted. The Ld. DR further submitted that the additional evidences now filed by the assessee are merely extracts from its own books of account and cannot independently establish the claim of the assessee. She submitted that the assessee has neither filed a copy of the alleged debit note before the lower authorities nor before the Tribunal. It was further submitted that the assessee has also failed to furnish confirmation from CTIL E Housing Private Limited to establish that there was in fact a genuine accounting mistake. Accordingly, she submitted that no further opportunity deserves to be granted to the assessee and the order of the Ld. CIT(A) deserves to be upheld. 7. We have heard the rival submissions and perused the material available on record. At the outset, we find that the assessee has filed certain additional evidences before us in the form of ledger accounts, purchase register and credit note register. The assessee claims that these documents support its contention that the difference between the purchases reflected in the books of account and the GST returns arose on account of an inadvertent accounting error relating to a debit note

issued by CTIL E Housing Private Limited. In our considered opinion, the additional evidences sought to be filed by the assessee have a direct bearing on the issue involved in the present appeal and are necessary for proper adjudication of the dispute. Accordingly, in the interest of substantial justice, the additional evidences filed by the assessee are admitted. At the same time, we also find merit in the contention of the Ld. DR that the assessee has not furnished complete supporting evidences to substantiate its claim. In particular, the assessee has not produced the copy of the alleged debit note/credit note, reconciliation thereof with its books of account, nor any confirmation from CTIL E Housing Private Limited supporting the explanation advanced before us. We further note that there is no dispute that both the lower authorities had granted sufficient opportunities to the assessee to produce the necessary documentary evidences in support of its claim. Despite such opportunities, the assessee failed to furnish complete details before the authorities below. Therefore, the assessee cannot be said to be entirely free from blame in the matter. However, considering the nature of the dispute, the additional evidences now placed before us and keeping in view the principles of natural justice, we are of the considered view that one final opportunity deserves to be granted to the assessee to substantiate its claim before the Ld. AO. Accordingly, we set aside the impugned order of the Ld. CIT(A) and restore the matter to the file of the Ld. AO for fresh adjudication. The assessee shall be at liberty to file all such documentary evidences as it may deem necessary to substantiate its claim. The assessee is specifically directed to furnish:

(i) a copy of the alleged debit note/credit note issued by CTIL E Housing Private Limited; (ii) complete reconciliation of the said debit note/credit note with the books of account of the assessee; (iii) confirmation from CTIL E Housing Private Limited supporting the transactions in question; and (iv) all other documents and information that may be called for by the Ld. A.O during the remand proceedings. 8. The Ld. AO shall verify the claim of the assessee on the basis of the evidences to be furnished and thereafter decide the issue afresh in accordance with law after providing reasonable opportunity of being heard to the assessee. We make it clear that in case the assessee fails to furnish the requisite evidences during the remand proceedings, the Ld. AO shall be at liberty to draw appropriate inference in accordance with law. Accordingly, the grounds raised by the assessee are allowed for statistical purposes. 9. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the Open Court on 17th June, 2026. Sd/- Sd/- (RVISH SOOD) (MADHUSUDAN SAWDIA) JUDICIAL MEMBER ACCOUNTANT MEMBER Hyderabad, dated 17th June, 2026. Vinodan/sps

Copy to: S.No Addresses 1 M/s. PVV INFRA LIMITED 501 5th Floor My Home Tycoon, Lifestyle Building, Begumpet S.O ,Lifestyle Building. Begumpet S.O Begumpet S.O Secunderabad, 500016,Telangana 2 DC/ACIT Circle 5(1) IT Towers, Hyderabad 500004 3 Pr. CIT - Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File By Order VADREVU Digitally signed by VADREVU PRASADA PRASADA RAO Date: 2026.06.17 RAO 17:16:39 +05'30'