SHANKAR LAL AGARWAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-16(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri K. Narasimha Chary

section 68 or not in case of NR Portfolio, obtrusive. Similarly bank statements provided by assessee to prove genuineness of transaction cannot be considered in Page 23 of 27 view of judgment of Hon'ble Court in case of Pratham Telecom India Pvt. Ltd. Wherein it was stated that bank statement is not sufficient enough to discharge burden. Regarding failure

ISHOO NARANG,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.450/Hyd/2022 & S.A. No.1/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Ishoo Narang Vs. Dy. Cit Hyderabad Circle 2(1) Pan:Aaupn9082B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Smt. Th Vijaya Lakshmi, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/08/2024 घोषणा की तारीख/Pronouncement: 25/09/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 15/07/2022 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2014-15. 2. The Assessee Has Raised The Following Grounds: “1. The Ld. Cit(A) Erred In Dismissing The Appeal. 2. The Ld.Cit(A) Erred In Holding That Al The Mandatory Preconditions Before Reopening Of Assessment U/S 147 Of The Act Were Duly Complied & Met With By The A.O.

bogus in nature is devoid of any merit. The learned Page 15 of 26 ITA No 450 of 2022 and SA NO 1 of 2024 Ishoo Narang CIT (A) after considering the relevant facts has rightly sustained the addition made by the Assessing Officer and their order should be upheld. 10. We have heard both the parties, perused the material

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

26,864/- after making certain additions/disallowances, viz. (i). disallowance under section 14A r.w Rule 8D, after taking cognizance of the fact that the assessee company had earned exempt dividend income of Rs. 13.20 crore during the year from its investments, and rejecting its claim of not having incurred any expenditure and computing the disallowance at 1% of the annual average

KIRAN BALA GUPTA,HYDERABAD vs. ITO, WARD-10(1), HYDERABAD

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.341/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2012-13) Smt. Kiran Bala Gupta, Vs. Income Tax Officer, Hyderabad. Ward-10(1), Pan: Ahvpg6893K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Av Raghuram, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 20/12/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/08/2022 For The Assessment Year (Ay) 2012-13. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

bogus. Also, the Ld. AR submitted that though it was the claim of the assessee that she acquired the jewellery in June, 1998 but had no material to substantiate her said claim except for the statement of her Mother, therefore, the AO had declined to accept the same primarily for the reason that no Wealth Tax returns in support thereof

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

26,864/-\nafter making certain additions/disallowances, viz. (i). disallowance\nunder section 14A r.w Rule 8D, after taking cognizance of the fact that\nthe assessee company had earned exempt dividend income of Rs.\n13.20 crore during the year from its investments, and rejecting its claim\nof not having incurred any expenditure and computing the disallowance\nat 1% of the annual average

SRUJITHA ANNAPAREDDY,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-12(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No.253/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Surjitha Annapareddy Vs. Income Tax Officer Secunderabad Ward 12(1) Pan:Bnwpa6703L Hydrabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Y Srikanth Reddy, Dr सुनवाई की तारीख/Date Of Hearing: 22/05/2024 घोषणा की तारीख/Pronouncement: 22/05/2024

purchased shares of MG Ltd. and on its amalgamation, was allotted shares of AG Ltd. in exchange for its existing holding and whose cost of acquisition has been claimed as eligible deduction and net sale consideration has been claimed as exempt as long-term capital gains. (Para 18) The AO has started with the conclusion, that the assessee is involved

BIKASH KUMAR KEDIA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.707/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Subhash Kumar Kedia Vs. Asstt. C. I. T. Hyderabad Central Circle 3(1) Pan:Afvpk8915Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No. 405/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Vs. Shri Bikash Kumar Asstt. C. I. T. Kedia Hyderabad Central Circle 3(1) Pan:Afapk8794E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Vamshi Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 29/10/2024 आदेश/Order Per Manjunatha, G. A.M These Two Appeals Filed By Different Assessees Are Directed Against The Separate, But Identical Orders Dated 31/01/2020 Of The Learned Cit (A)-11, Hyderabad Relating To Page 1 Of 33

Section 260-A of the Act, 1961.” 16. Similar view has been taken by the Hon'ble Supreme Court in the case of CIT (Central) vs. Sunita Dhadda in Special Leave Petition (Civil) Nos.9432/2018 dated 28/03/2018 wherein the Hon'ble Supreme Court has upheld the order of the Hon'ble Rajasthan High Court. 17. Coming back to the case

SUBHASH KUMAR KEDIA,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.707/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Subhash Kumar Kedia Vs. Asstt. C. I. T. Hyderabad Central Circle 3(1) Pan:Afvpk8915Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No. 405/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Vs. Shri Bikash Kumar Asstt. C. I. T. Kedia Hyderabad Central Circle 3(1) Pan:Afapk8794E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Vamshi Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 29/10/2024 आदेश/Order Per Manjunatha, G. A.M These Two Appeals Filed By Different Assessees Are Directed Against The Separate, But Identical Orders Dated 31/01/2020 Of The Learned Cit (A)-11, Hyderabad Relating To Page 1 Of 33

Section 260-A of the Act, 1961.” 16. Similar view has been taken by the Hon'ble Supreme Court in the case of CIT (Central) vs. Sunita Dhadda in Special Leave Petition (Civil) Nos.9432/2018 dated 28/03/2018 wherein the Hon'ble Supreme Court has upheld the order of the Hon'ble Rajasthan High Court. 17. Coming back to the case

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. R.K.INFRACORP PRIVATE LIMITED, HYDERABAD

bogus purchases in its books of accounts. The\nAO, based on his aforesaid observations, which though were explicitly\nrecorded only in context of the aforementioned three entries, however\ndrew adverse inferences with respect to 24 entries mentioned in the\nseized document, viz., Annexure A-1/Pages 01-02 and made an addition\nof Rs.20,35,50,000/- by treating

R.K.INFRACORP PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

bogus purchases in its books of accounts. The\nAO, based on his aforesaid observations, which though were explicitly\nrecorded only in context of the aforementioned three entries, however\ndrew adverse inferences with respect to 24 entries mentioned in the\nseized document, viz., Annexure A-1/Pages 01-02 and made an addition\nof Rs.20,35,50,000/- by treating

TARUN KUMAR GOYAL (HUF),HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Manjunatha. G & Shri K. Narasimha Chary

section 143(3) of the Act was completed by order dated 03/11/2016 by making an addition of Rs. 36,83,077/- which represented the sale consideration of shares, under the head "Income from Other Sources." Page 2 of 8 ITA No.2093/Hyd/2017 & 455/Hyd/2020 Tarun Kumar Goyal (HUF) 4. Aggrieved by such an ac"on of the learned Assessing Officer, assessee preferred

TARUN KUMAR GOYAL (HUF) ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Manjunatha. G & Shri K. Narasimha Chary

section 143(3) of the Act was completed by order dated 03/11/2016 by making an addition of Rs. 36,83,077/- which represented the sale consideration of shares, under the head "Income from Other Sources." Page 2 of 8 ITA No.2093/Hyd/2017 & 455/Hyd/2020 Tarun Kumar Goyal (HUF) 4. Aggrieved by such an ac"on of the learned Assessing Officer, assessee preferred

KINETA GLOBAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, 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, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

purchases which the assessee company had claimed to have made from M/s. Sauve Corporation India Pvt. Ltd, were bogus and, thus, the entire amount of bogus expenditure was treated by him as the income of the assessee company. The AO, based on his aforesaid observations after reducing the profit of Rs. 18,17,636/-, that the assessee company had claimed

KUPPAM EDUCATIONAL SOCIETY,KUPPAM vs. INCOME TAX OFFICER (EXEMPTIONS), TIRUPATI

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

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

26 days in filing of this appeal is condoned and the appeal is admitted for adjudication. 3. The grounds raised by the assessee reads as under : “ 1. The ground on which the assessing officer has disallowed the depreciation claim of the appellant society as an application of income is not at all sustainable for the simple reason that the depreciation

VISWANADH KANDULA,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, appeals of the assessee for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, Dated 04/01/2023 In Case Of Exel Group Of Companies Including The Assessee For The A.Ys 2014-15 To 2019-20 Respectively. Since Common Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

purchase or acquisition of any asset. Therefore, the business transactions of sale of scrap or commission income etc, as well as the expenditure incurred in relation to the business activity would not constitute of an asset in terms of section 149(1)(b) of the Act. It is also a matter of fact and record that these transactions as found

GOVIND KUMAR AGARWAL ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(5), HYDERABAD

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumars.No Ita No Assessee Revenue A.Y 1 125/Hyd/2020 Shri Govind Kumar Income Tax 2015-16 Agarwal, Hyderabad Officer Ward 4(2) Pan:Aempa6821K Hyderabad 2 1940/Hyd/2018 Shri Govind Kumar Income Tax 2014-15 Agarwal, Hyderabad Officer Ward 4(2) Pan:Aempa6821K Hyderabad 3 1941/Hyd/2018 Shri Naresh Kumar Income Tax 2015-16 Agarwal, Officer Ward Secunderabad 10(2) Hyderabad Pan:Adhpa8519L 4 1942/Hyd/2018 Shri Sumeet Kumar Income Tax 2015-16 Agarwal, Officer Ward Secunderabad 10(2) Hyderabad Pan:Adhpa8516F 5 704/Hyd/2019 Smt. Saroj Agarwal, Income Tax 2015-16 Hyderabad Officer Ward 4(2) Pan:Adhpa8513A Hyderabad 6 705/Hyd/2019 Shri Vikas Kumar Income Tax 2015-16 Agarwal Hyderabad Officer Ward Pan:Adhpa8515G 4(2)Hyderabad 7 89/Hyd/2022 Shri Nageswara Rao Acit, Central 2015-15 Pinneti, Hyderabad Circle 1(2) Pan:Acupp6464D Hyderabad 8 167/Hyd/2018 Shri Abhishek Income Tax 2014-15 Agarwal, Hyderabad Officer Pan:Adypa7514N Ward 16(2) Hyderabad Assessee By: Shri K.A. Sai Prasad, Ca (S.No.1 To 6), Shri P. Vinod, Advocate (S.No.7) & Shri S. Rama Rao, Advocate (S.No.8) Revenue By: Shri Ch V Gopinath, Cit(Dr)

bogus transactions and aimed only to bring unaccounted money in the guise of exempted long term capital gain and paper work has been done merely to give a colour of authenticity to the transaction and by creating a façade of legitimate transactions. Thus, the transactions made with these paper companies were treated as fictitious and the amount of Rs.8

NARESH KUMAR AGARWAL ,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-10(2), HYDERABAD

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumars.No Ita No Assessee Revenue A.Y 1 125/Hyd/2020 Shri Govind Kumar Income Tax 2015-16 Agarwal, Hyderabad Officer Ward 4(2) Pan:Aempa6821K Hyderabad 2 1940/Hyd/2018 Shri Govind Kumar Income Tax 2014-15 Agarwal, Hyderabad Officer Ward 4(2) Pan:Aempa6821K Hyderabad 3 1941/Hyd/2018 Shri Naresh Kumar Income Tax 2015-16 Agarwal, Officer Ward Secunderabad 10(2) Hyderabad Pan:Adhpa8519L 4 1942/Hyd/2018 Shri Sumeet Kumar Income Tax 2015-16 Agarwal, Officer Ward Secunderabad 10(2) Hyderabad Pan:Adhpa8516F 5 704/Hyd/2019 Smt. Saroj Agarwal, Income Tax 2015-16 Hyderabad Officer Ward 4(2) Pan:Adhpa8513A Hyderabad 6 705/Hyd/2019 Shri Vikas Kumar Income Tax 2015-16 Agarwal Hyderabad Officer Ward Pan:Adhpa8515G 4(2)Hyderabad 7 89/Hyd/2022 Shri Nageswara Rao Acit, Central 2015-15 Pinneti, Hyderabad Circle 1(2) Pan:Acupp6464D Hyderabad 8 167/Hyd/2018 Shri Abhishek Income Tax 2014-15 Agarwal, Hyderabad Officer Pan:Adypa7514N Ward 16(2) Hyderabad Assessee By: Shri K.A. Sai Prasad, Ca (S.No.1 To 6), Shri P. Vinod, Advocate (S.No.7) & Shri S. Rama Rao, Advocate (S.No.8) Revenue By: Shri Ch V Gopinath, Cit(Dr)

bogus transactions and aimed only to bring unaccounted money in the guise of exempted long term capital gain and paper work has been done merely to give a colour of authenticity to the transaction and by creating a façade of legitimate transactions. Thus, the transactions made with these paper companies were treated as fictitious and the amount of Rs.8

ABHISHEK AGARWAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-16(2), HYDERABAD

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumars.No Ita No Assessee Revenue A.Y 1 125/Hyd/2020 Shri Govind Kumar Income Tax 2015-16 Agarwal, Hyderabad Officer Ward 4(2) Pan:Aempa6821K Hyderabad 2 1940/Hyd/2018 Shri Govind Kumar Income Tax 2014-15 Agarwal, Hyderabad Officer Ward 4(2) Pan:Aempa6821K Hyderabad 3 1941/Hyd/2018 Shri Naresh Kumar Income Tax 2015-16 Agarwal, Officer Ward Secunderabad 10(2) Hyderabad Pan:Adhpa8519L 4 1942/Hyd/2018 Shri Sumeet Kumar Income Tax 2015-16 Agarwal, Officer Ward Secunderabad 10(2) Hyderabad Pan:Adhpa8516F 5 704/Hyd/2019 Smt. Saroj Agarwal, Income Tax 2015-16 Hyderabad Officer Ward 4(2) Pan:Adhpa8513A Hyderabad 6 705/Hyd/2019 Shri Vikas Kumar Income Tax 2015-16 Agarwal Hyderabad Officer Ward Pan:Adhpa8515G 4(2)Hyderabad 7 89/Hyd/2022 Shri Nageswara Rao Acit, Central 2015-15 Pinneti, Hyderabad Circle 1(2) Pan:Acupp6464D Hyderabad 8 167/Hyd/2018 Shri Abhishek Income Tax 2014-15 Agarwal, Hyderabad Officer Pan:Adypa7514N Ward 16(2) Hyderabad Assessee By: Shri K.A. Sai Prasad, Ca (S.No.1 To 6), Shri P. Vinod, Advocate (S.No.7) & Shri S. Rama Rao, Advocate (S.No.8) Revenue By: Shri Ch V Gopinath, Cit(Dr)

bogus transactions and aimed only to bring unaccounted money in the guise of exempted long term capital gain and paper work has been done merely to give a colour of authenticity to the transaction and by creating a façade of legitimate transactions. Thus, the transactions made with these paper companies were treated as fictitious and the amount of Rs.8