ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

153, the A.O. shall make an order of assessment or reassessment in respect of each assessment year falling within six assessment years referred to in clause (b) of sub- section (1) of Section 153A within a period of twelve months from the end of the financial year in which the last of the authorisations for search under Section

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

KAVERI POLYMERS,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

153, in the case of a person68 where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within such period, as may be specified in the notice

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

153, in the case of a person68 where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within such period, as may be specified in the notice

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE-1(3),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

153, in the case of a person68 where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within such period, as may be specified in the notice

DCIT, CIRCLE-17(1),HYDERABAD, HYDERABAD vs. FARMAX INDIA LTD., HYD, R.R.DIST

In the result, the appeal filed by the assessee is dismissed and the appeal filed by the revenue is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2009-10 Farmax India Limited Vs. Dcit,Circle-1(3) 4Th Floor, Alluri Trade Centre I.T.Towers, A.C.Guards Bhagayanagar Colony Masab Tank Opp.Kphb Colony Hyderabad Kukatpally Hyderabad-500 072

purchase the shares for substantial amount. The decision of the Hon’ble Supreme Court in the case of M/s. Lovely Exports Pvt.Ltd. was also considered by the Hon’ble Delhi High Court. In the instant case, the appellant neither produced the shareholders nor their lenders for examination by the Assessing Officer, neither the identity is proved nor the creditworthiness

FARMAX INDIA LIMITED,,HYDERABAD vs. DCIT, CIRCLE 1(3), HYDERABAD

In the result, the appeal filed by the assessee is dismissed and the appeal filed by the revenue is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2009-10 Farmax India Limited Vs. Dcit,Circle-1(3) 4Th Floor, Alluri Trade Centre I.T.Towers, A.C.Guards Bhagayanagar Colony Masab Tank Opp.Kphb Colony Hyderabad Kukatpally Hyderabad-500 072

purchase the shares for substantial amount. The decision of the Hon’ble Supreme Court in the case of M/s. Lovely Exports Pvt.Ltd. was also considered by the Hon’ble Delhi High Court. In the instant case, the appellant neither produced the shareholders nor their lenders for examination by the Assessing Officer, neither the identity is proved nor the creditworthiness

REEMA AGARWAL,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, appeal of the Assessee is allowed

153 taxmann.com 578 (Allahabad-HC). He has also\nrelied upon the Judgment of Hon'ble Supreme Court in the\ncase of Pr. CIT vs. Kishore Kumar Mohapatra [2024] 162\ntaxmann.com 5 (SC) whereby the SLP filed by the Revenue\nagainst the Judgment of Hon'ble Orissa High Court has\nbeen dismissed reported_in_[2024] 162 taxmann.com 4\n(Orissa

GIRISH REDDY ALTHURI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri R.K. Panda & Shri Laliet Kumar

3) r.w.s 153A is not barred by limitation and/or illegal within the meaning of first proviso to section 153A. 4. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in relying on the statements of various persons obtained behind the back of the appellant without affording opportunity of cross examining those