SUKESINI KUMILI,HYDERABAD vs. ITO, WARD-15(1), HYDERABAD

In the result, the appeals of the assessee in ITA no

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaappeal In Ita Nos. Assessee Revenue A.Ys 1536 To 1539/ Hyd/2025 Sukesini Kumili, Hyderabad Pan:Ckmpk5466J Income Tax Officer Ward 15(1), Hyderabad 2015-16 & 2016-17 निर्धारिती द्वारा /Assessee By: Advocate Shri S. Rama Rao राजस्व द्वारा / Revenue By:: || Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: | 07/01/2016 घोषणा की तारीख / Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili ("The Assessee") Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

Section 148 of the Income Tax Act, 1961. 2. The gist of the information is as under: Page 5 of 20 ITA Nos. 1536 to 1539 of 2025 Sukesini Kumili CKMPK5466J-SUKESINI KUMIL Α.Υ. 2015-16 TBA/AST/F/148A/2022-23/1042593845(1) AIR-001 Deposited cash of Rs. 10,00,000 or more in a saving bank account BANK OF BARODA 1 AMOUNT

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:

2. Also, the revenue has raised an additional grounds of appeal, as under: “Notice u/s 148 issued on 29/07/2022, in respect of initial notice under section 148, dated 28/06/2021, and reply on 01/06/2022, is barred by limitation as per the ratio laid down by the Hon’ble Supreme Court in the case of Union of India vs. Rajeev Bansal

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)

148 for this AY 2018-19. 14. The Ld. CIT (A) erred in upholding that the Ld. AO ought to considered the fact that the assessee had deducted TDS properly from their vendors and filed 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

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)

TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted the provisions of section 40(a)(ia) of the Act; and (ii) and though the assessee company had during the subject year carried out international transactions with its Associated Enterprises (AEs) of Rs.23,97,35,320/-, but the AO in the course

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

SIVA SANKARA REDDY TUNGA,HYDERABAD. vs. ITO., WARD - 14(1), HYDERABAD.

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

Bench: Us:

TDS Statement): Rs.1,25,775/-; and (iv) time deposit exceeding Rs.2 lakhs or more with Andhra Bank: Rs.26,00,000/- , but had not filed his return of income for the subject year, i.e., AY 2016- 17, issued notice under section 148A(b) of the Act. Thereafter, the AO passed an order under section 148A(d) of the Act, dated 25/03/2023

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

2) of the I.T. Act. 6. The belief entertained is not the A.O’s own belief but borrowed belief of the Investigation Wing Kolkata. The proceedings of reopening are invalid in law. :- 3 -: ITA No.. 497/Hyd/2019 and CO 16/H/2019 Coastal Projects Pvt. Ltd., Hyd. 7. The grounds of appeal raised by the A.O do not arise either from

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED ,HYDERABAD vs. INCOME TAX OFFICERS ,WARD -1(2), HYDERABAD

In the result, appeal of the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2012-13 Country Club Hospitality & Vs. Income-Tax Officer, Ward Holidays Ltd., Hyderabad. – 1(2), Hyderabad. Pan – Aaacc 8276 B (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Rohit Mujumdar Date Of Hearing: 08/02/2022 Date Of Pronouncement: 17/02/2022

TDS which are relevant for the AY 2012-13. Whereas the language used in section 147 is that “where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment

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

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

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

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

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

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

SKANDHANSHI DEVELOPERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

TDS, which attracts disallowance u/sec.40(a)(ia) of the Income Tax Act, 1961. Therefore, considering the overall scenario including relevant books of accounts maintained by the assessee and incriminating material found during the course of search observed that, the profit percentage of undisclosed turnover found during the course of search proceedings should be more than the profit percentage

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

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

TDS = 0 Advance tax paid = 0 Tax paid u/s 140A 0 Regular Tax Paid 0 TOTAL TAXES PAID = 0 0 Refund Issued U/s 143(1)/143(3)/154/etc = 2,93,41,470/- Balance tax payable Round off 8. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT(A), who partly allowed the appeal of assessee after

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

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

TDS = 0 Advance tax paid = 0 Tax paid u/s 140A 0 Regular Tax Paid 0 TOTAL TAXES PAID = 0 0 Refund Issued U/s 143(1)/143(3)/154/etc = 2,93,41,470/- Balance tax payable Round off 8. Feeling aggrieved with the order of AO, assessee carried the matter before ld.CIT(A), who partly allowed the appeal of assessee after