V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

TDS applicable as per law. The assessee also furnished affidavits from both the subcontract workers where they have denied statements given during the course of survey under Section 133A

V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

TDS applicable as per law. The assessee also furnished affidavits from both the subcontract workers where they have denied statements given during the course of survey under Section 133A

V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

TDS applicable as per law. The assessee also furnished affidavits from both the subcontract workers where they have denied statements given during the course of survey under Section 133A

S A BUILDERS & DEVELOPERS,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-2(1) , HYDERABAD

In the result, Ground Nos

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.258 & 259/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2016-17 & 2017-18) M/S. S.A. Builders & Developers, Vs. Acit Hyderabad Central Circle 2(1) Pan:Acufs3331A Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.295 & 296/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2016-17 & 2017-18) Acit Vs. M/S. S.A. Builders & Central Circle 2(1) Developers, Hyderabad Hyderabad Pan:Acufs3331A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/02/2025 घोषणा की तारीख/Pronouncement: 15/05/2025 आदेश/Order Per Bench: These Two Sets Of Cross Appeals Are Directed Against The Two Separate Orders Of The Learned Cit (A)-12, Hyderabad Both Dated 29/04/2022, Arising From The Assessment Framed U/S 143(3) R.W.S. 153A Of The I.T. Act, 1961 For The A.Ys 2016-17 & Page 1 Of 56

133A is not a search under section 132 as both operate in their respective fields and it is legally not permissible to equate both the actions as same. 7. The learned CIT(A) should have appreciated that no valuable or books of account belonging to the firm were seized from the residential premises of Syed Akthar (partner). 8. The learned

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(1), HYDERABAD vs. S A BUILDERS AND DEVELOPERS, HYDERABAD

In the result, Ground Nos

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.258 & 259/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2016-17 & 2017-18) M/S. S.A. Builders & Developers, Vs. Acit Hyderabad Central Circle 2(1) Pan:Acufs3331A Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.295 & 296/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2016-17 & 2017-18) Acit Vs. M/S. S.A. Builders & Central Circle 2(1) Developers, Hyderabad Hyderabad Pan:Acufs3331A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/02/2025 घोषणा की तारीख/Pronouncement: 15/05/2025 आदेश/Order Per Bench: These Two Sets Of Cross Appeals Are Directed Against The Two Separate Orders Of The Learned Cit (A)-12, Hyderabad Both Dated 29/04/2022, Arising From The Assessment Framed U/S 143(3) R.W.S. 153A Of The I.T. Act, 1961 For The A.Ys 2016-17 & Page 1 Of 56

133A is not a search under section 132 as both operate in their respective fields and it is legally not permissible to equate both the actions as same. 7. The learned CIT(A) should have appreciated that no valuable or books of account belonging to the firm were seized from the residential premises of Syed Akthar (partner). 8. The learned

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. ACIT, TDS CIRCLE (TDS)-1(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2018-

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent

TDS under various sections of chapter XVII-B of the Income Tax Act, 1961 (‘the Act’). A survey under section 133A

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. ACIT TDS, CIRCLE(TDS-1(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2018-

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent

TDS under various sections of chapter XVII-B of the Income Tax Act, 1961 (‘the Act’). A survey under section 133A

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. ACIT TDS, CIRCLE (TDS)-1(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2018-

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent

TDS under various sections of chapter XVII-B of the Income Tax Act, 1961 (‘the Act’). A survey under section 133A

EXEL RUBBER PRIVATE LIMITED,K.V.RANGAREDDY vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

TDS Range-2, Hyd 08 DV Ramakrishna ITI DDIT(Inv.), Unit-1(2), Hyderabad 09 Kilaru Viranjancyulu ITI DDIT(Inv.), Unit-1(2), Hyderabad 10 Rajesh Kumar Meena ITI DDIT(Inv.), Unit-1(4), Hyderabad 11 Ravindra Reddy Avula ITI DDIT(Inv.), Unit-1(4), Hyderabad 12 Dandaboina Lingam ITI DDIT(Inv.), Unit-II(2), Hyderabad 13 Ravi Kumar Saroj

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

TDS Range-2, Hyd 08 DV Ramakrishna ITI JDIT(Inv.), Unit-IV, Vijayawada 09 Kilaru Viranjancyulu ITI DDIT(Inv.), Unit-1(2), Hyderabad 10 Rajesh Kumar Meena ITI DDIT(Inv.), Unit-1(4), Hyderabad 11 Ravindra Reddy Avula ITI DDIT(Inv.), Unit-1(4), Hyderabad 12 Dandaboina Lingam ITI DDIT(Inv.), Unit-II(2), Hyderabad 13 Ravi Kumar Saroj

FSL PROJECTS LIMITED (FORMERLY FRONTLINE SOFT LIMITED),HYDERABAD vs. DCIT, CIRCLE 14(3) (TDS), HYDERABAD

In the result, subject to the above observations, appeal of the assessee is allowed

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

133A of the Act, it was found that the assessee made payments to IGTL Solutions (USA) and True Dial Technologies INC, without deducting the tax at source under section 195 read with section 9(1)(vi) and (vii) of the Act. According to the learned Assessing Officer the assessee having not made any deduction of tax at source without making

S A BUILDERS & DEVELOPERS ,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-1(2) , HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

133A is not a search under section 132 as both operate in their respective fields and it is legally not permissible to equate both the actions as same. 7. The learned CIT(A) should have appreciated that no valuable or books of account belonging to the firm were seized from the residential premises of Syed Akthar (partner). 8. The learned

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(1) , HYDERABAD vs. S A BUILDERS AND DEVELOPERS , HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

133A is not a search under section 132 as both operate in their respective fields and it is legally not permissible to equate both the actions as same. 7. The learned CIT(A) should have appreciated that no valuable or books of account belonging to the firm were seized from the residential premises of Syed Akthar (partner). 8. The learned

FSL PROJECTS LIMITED (FORMERLY FRONTLINE SOFT LIMITED),HYDERABAD vs. DCIT., CIRCLE14(3) (TDS), HYDERABAD

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

Bench: Shri S. Rifaur Rahman & Shri K.Narasimha Chary

133A of the Income Tax Act, 1961 (for short “the Act”), it was found that the assessee made payments to IGTL Solutions (USA) and True Dial Technologies INC, without deducting the tax at source under section 195 read with section 9(1)(vi) and (vii) of the Act. According to the learned Assessing Officer the assessee having not made

IDEA CELLULAR LTD, HYD,HYDERABAD vs. ACIT, TDS CIRCLE, WARD-1(1), HYD, HYDERABAD

In the result, both the appeals under consideration are partly allowed for statistical purposes

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

133A was conducted in the case on 16/02/2015. Subsequently, proceedings u/s 201(1) and 201(1A) of the Act, were initiated by issuing a notice on 23/02/2015. In response, the assessee furnished the information called for. On verification of the information provided, AO noticed that the assessee was not deducting tax at source in the case of commission payments

IDEA CELLULAR LTD, HYD,HYDERABAD vs. ACIT, TDS CIRCLE, WARD-1(1), HYD, HYDERABAD

In the result, both the appeals under consideration are partly allowed for statistical purposes

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

133A was conducted in the case on 16/02/2015. Subsequently, proceedings u/s 201(1) and 201(1A) of the Act, were initiated by issuing a notice on 23/02/2015. In response, the assessee furnished the information called for. On verification of the information provided, AO noticed that the assessee was not deducting tax at source in the case of commission payments

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

TDS and VAT payable under section 43B of the Act: Rs. 6,08,694/-; and (v) addition of Rs.3,34,246/- on account of estimated profit on undisclosed sales: Rs.3,34,246/-, but at the same time declined the assessee’s claim regarding the validity of jurisdiction that was assumed by the AO, while initiating proceedings under section

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

TDS returns, also remitted GST and filed necessary returns of the significant value. 15. The Ld. CIT(A) ought to have considered that the action of the AO in rejecting the books of accounts u/s 145 is not correct and bad-in- law. 16. The Ld. GIT (A) erred in upholding that the Ld. AO estimating the income