NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

147 of the Act dated 28-12- 2019 is invalid and liable to be quashed. Thus, we quash the assessment order passed by the AO. 25. The other issues that came up for our consideration from ground nos. 4 to 8 of assessee’s appeal are relating to the addition of Rs.41,64,131/- towards finance cost being interest paid

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

147 of the Act dated 28-12- 2019 is invalid and liable to be quashed. Thus, we quash the assessment order passed by the AO. 25. The other issues that came up for our consideration from ground nos. 4 to 8 of assessee’s appeal are relating to the addition of Rs.41,64,131/- towards finance cost being interest paid

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

147 of the Act; c) Notice under section 143(2) of the Act was issued without providing opportunity to the Appellant to file its objections against the reasons for reopening the assessment; d) Notice under section 142(1) of the Act was issued without issuing the notice under section 143(2) of the Act and the reasons for reopening

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. COASTAL PROJECTS PRIVATE LIMITED , HYDERABAD

In the result, the C.O. filed by the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 147 stipulates that the income chargeable to tax has escaped assessment on account of failure of the assessee to disclosure fully and truly the material facts relating to the assessment. After the search on 25-11-2011, the ADIT (Inv) had issued a Letter directing the appellant to furnish the complete details relating to subcontractors from Kolkata including Bright

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

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

147 deals with income\nescaping assessment, and Section 153A deals with\nassessment consequent to search and seizure under Section\n132, where any money, bullion, jewellery, valuable article or\nthings found as a result of the search. Therefore, in our\nconsidered view, when the Hon'ble Supreme Court, in very\ncategorical terms, held in light of the provisions of Section\n147

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

147 deals with income\nescaping assessment, and Section 153A deals with\nassessment consequent to search and seizure under Section\n132, where any money, bullion, jewellery, valuable article or\nthings found as a result of the search. Therefore, in our\nconsidered view, when the Hon'ble Supreme Court, in very\ncategorical terms, held in light of the provisions of Section\n147

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

In the result appeals filed by the Revenue\nITA

147 deals with income\nescaping assessment, and Section 153A deals with\nassessment consequent to search and seizure under Section\n132, where any money, bullion, jewellery, valuable article or\nthings found as a result of the search. Therefore, in our\nconsidered view, when the Hon'ble Supreme Court, in very\ncategorical terms, held in light of the provisions of Section\n147

DY.COMMISSIONER OF INCOME TAX, CIRCLE 2(2), HYDERBAD vs. SEW INFRASTUCTURE LIMITED, HYDERABAD

147 deals with income\nescaping assessment, and Section 153A deals with\nassessment consequent to search and seizure under Section\n132, where any money, bullion, jewellery, valuable article or\nthings found as a result of the search. Therefore, in our\nconsidered view, when the Hon'ble Supreme Court, in very\ncategorical terms, held in light of the provisions of Section\n147

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)

147 r.w.s 144B of the Income Tax Act, 1961 2 Bilwa Infrastructure Limited vs. ITO (for short, “the Act”), dated 26/03/2024 for the Assessment Year (AY) 2018-19. The assessee company has assailed the impugned order of the CIT(A) on the following grounds of appeal: “1.The order of the Ld. CIT (A) u/s 250 of the Act dt. 20/06/2025

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

147 of the Act. Notice under section 148 of the Act, dated 27/03/2021, was issued to the assessee company. In compliance, the assessee company filed its return of income on 21/10/2021, declaring its income at Rs. NIL. 3. During the course of the assessment proceedings, the AO issued notice under section 142(1) of the Act, dated 22/11/2021, calling upon

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued U/s 143(1)/143(3)/154/etc 2,00,81,620/- = Balance tax payable Round off ITA Nos.34 to 36/Hyd/2021 9. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued U/s 143(1)/143(3)/154/etc 2,00,81,620/- = Balance tax payable Round off ITA Nos.34 to 36/Hyd/2021 9. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued U/s 143(1)/143(3)/154/etc 2,00,81,620/- = Balance tax payable Round off ITA Nos.34 to 36/Hyd/2021 9. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT

ORBIT VENTURES,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued U/s 143(1)/143(3)/154/etc 2,00,81,620/- = Balance tax payable Round off ITA Nos.34 to 36/Hyd/2021 9. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT

ORBIT VENTURES,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued U/s 143(1)/143(3)/154/etc 2,00,81,620/- = Balance tax payable Round off ITA Nos.34 to 36/Hyd/2021 9. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT

ORBIT VENTURES,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

TDS = 0 Advance tax paid = 0 6,56,720/- Tax paid u/s 140A Regular Tax Paid 0 6,56,720/- TOTAL TAXES PAID = 0 Refund Issued U/s 143(1)/143(3)/154/etc 2,00,81,620/- = Balance tax payable Round off ITA Nos.34 to 36/Hyd/2021 9. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT

INDUR DEVELOPERS AND AGENCIES PRIVATE LIMITED ,VIJAYAWADA vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

Section 147 of the Act. 7. During the course of assessment proceedings, the Assessing Officer noticed that the real estate companies of Kapil Group have been accepting advance for sales of residential / commercial office space by entering into an MOU with potential customers. As per the MOU, the potential customer has to pay 80% of the sale consideration and choose

INDUR AVENUES AND FOODS PRIVATE LIMITED,NIZAMABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

Section 147 of the Act. 7. During the course of assessment proceedings, the Assessing Officer noticed that the real estate companies of Kapil Group have been accepting advance for sales of residential / commercial office space by entering into an MOU with potential customers. As per the MOU, the potential customer has to pay 80% of the sale consideration and choose