Jvr Retails Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle -2(1), Hyderabad
In the result, the appeal filed by the assessee is allowed
ITA 175/HYD/2021[2012-13]Status: DisposedITAT Hyderabad31 Jan 2023AY 2012-13
Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2012-13 Jvr Retails Private Limited Vs Dcit, Circle-2(1) C/O. Murali & Co. . Hyderabad Chartered Accountants 6-3-655/2/3, Somajiguda Hyderabad-500 082 Pan : Aaccv9428J (Appellant) (Respondent) Assessee By: Shri M.V.Joshi Appeared For P.Murali Mohan Rao, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.01.2023 Date Of Pronouncement: 31.01.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.03.2021 Passed U/S. 263 By The Learned Principal Commissioner Of Income Tax -2, Hyderabad Relating To A Y 2012-13. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Domestic Company Engaged In The Business Of Retails & Manufacturing Of Jewelry. It Filed Its Return Of Income Declaring Total Income Of Rs. 49,97,390/- On 08.09.2012 Which Was Processed U/S 143(1) On 21.02.2013. Subsequently, The Ao Reopened The Assessment By Recording Reasons As Per Provisions Of Section 147. The Reasons To Believe Which Was Put Up Before The Ld.Pcit-2 For Approval & Which Has Been Reproduced By The Ao In The Body Of The Assessment Order Read As Under:-
For Appellant: Shri M.V.Joshi appeared for P.Murali Mohan Rao, CAFor Respondent: Shri Jeevan Lal
Section 143(1)Section 143(3)Section 147Section 148Section 263Section 68
…s. CIT reported in 36 taxmann.com 348(Hyd.Trib) n) Sanspareils Greenlands(P.) Ltd. vs. CIT reported in 99 taxmann.com 222(Del.Trib) o) CIT vs. Mehrotra Brothers reported in 270 ITR 157 (MP.HC) p) CIT vs.Srinivasa Hatcheries (P.) Ltd.vs DCIT reported in [2002] 81 ITD 36(Hyd) (Hyd.Trib) q) Development Credit Bank Ltd. reported in [2011] 196 taxmann 329 12. The ld.DR on the other hand strongly supported the order of the ld.PCIT. He submitted that a perusal of the balance sheet of the assessee company shows that during the FY 2011-12, the share capital of the company was increased from Rs. 11 JVR Retails Pvt.Ltd. 3…