DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED , HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

20,81,719/- from M/s Jagannath Agro Ltd. and such financial transaction has been reported to be bogus in nature, therefore, notice u/s 148A was issued and called upon the assessee to file objections, if any for proposed reassessment. Further upon consideration of the objections, if any filed by the assessee, order u/s 148A(d) dated 28.07.2022 was passed

AMARAVATI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation wing

AMARAVATI ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation wing

AMARAVATI,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation wing

AMARAVATI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation wing

VITHALDAS AND COMPANY (SICNE DISSOLVE), HYD,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD, HYDERABAD

Appeals are partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under challenge. 5. Learned counsel’s first and foremost vehement contention seeks to quash the impugned reopening without recording the reasons based on tangible material which could even indicate assessee’s taxable income to have declared assessment. We find

VITHALDAS AND COMPANY (SICNE DISSOLVE), HYD,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD, HYDERABAD

Appeals are partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under challenge. 5. Learned counsel’s first and foremost vehement contention seeks to quash the impugned reopening without recording the reasons based on tangible material which could even indicate assessee’s taxable income to have declared assessment. We find

VITHALDAS AND COMPANY (SICNE DISSOLVE), HYD,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD, HYDERABAD

Appeals are partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under challenge. 5. Learned counsel’s first and foremost vehement contention seeks to quash the impugned reopening without recording the reasons based on tangible material which could even indicate assessee’s taxable income to have declared assessment. We find

BASANTH LAL SAH,HYDERABAD vs. ITO., WARD-11(1), HYDERABAD

Bench: Us :

20 Basanth Lal Sah. from them. Apart from that, the Ld. AR has submitted that the non-compliance of the aforementioned parties to the notices issued under Section 133(6) of the Act could not have been pressed into service by the authorities below for doubting the authenticity of the purchase transactions. Elaborating further on his contention

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

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

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

section 40A. Instead of rejecting the turnover, he proceeded to disallow only the associated financial cost. He disallowed the interest cost in proportion to the purchases with related and unrelated parties. 17.2 However, DRP remitted this issue of disallowance of interest back to the AO to recalculate the interest properly and by following cash flow on day to day basis

VITHALDAS AND COMPANY ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1, HYDERABAD

Appeal is partly allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under challenge. 5. Learned counsel’s first and foremost vehement contention seeks to quash the impugned reopening without recording the reasons based on tangible material which could even indicate assessee’s taxable income to have declared assessment. We find

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

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

bogus/ accommodation entries of purchase bills/unexplained and unverifiable expenses with various vendors have been pointed in a show-cause notice is erroneous. The disallowance made by the learned AO is not based on any specific finding and is devoid of appreciation of the details submitted by the Appellant. 2.2.2. In this regard, we wish to submit that during the assessment

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELCOM INFRASTRUTURE PRIVATE LIMITED , HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

bogus/ accommodation entries of purchase bills/unexplained and unverifiable expenses with various vendors have been pointed in a show-cause notice is erroneous. The disallowance made by the learned AO is not based on any specific finding and is devoid of appreciation of the details submitted by the Appellant. 2.2.2. In this regard, we wish to submit that during the assessment

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

bogus/ accommodation entries of purchase bills/unexplained and unverifiable expenses with various vendors have been pointed in a show-cause notice is erroneous. The disallowance made by the learned AO is not based on any specific finding and is devoid of appreciation of the details submitted by the Appellant. 2.2.2. In this regard, we wish to submit that during the assessment

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

bogus/ accommodation entries of purchase bills/unexplained and unverifiable expenses with various vendors have been pointed in a show-cause notice is erroneous. The disallowance made by the learned AO is not based on any specific finding and is devoid of appreciation of the details submitted by the Appellant. 2.2.2. In this regard, we wish to submit that during the assessment

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

bogus/ accommodation entries of purchase bills/unexplained and unverifiable expenses with various vendors have been pointed in a show-cause notice is erroneous. The disallowance made by the learned AO is not based on any specific finding and is devoid of appreciation of the details submitted by the Appellant. 2.2.2. In this regard, we wish to submit that during the assessment

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELCOM INFRASTRUTURE PRIVATE LIMITED , HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

bogus/ accommodation entries of purchase bills/unexplained and unverifiable expenses with various vendors have been pointed in a show-cause notice is erroneous. The disallowance made by the learned AO is not based on any specific finding and is devoid of appreciation of the details submitted by the Appellant. 2.2.2. In this regard, we wish to submit that during the assessment

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

purchased for Rs. 1 lakh and when the investments in shares became eligible for long term capital gains, it was sold for Rs. 29 lakhs during the period when the general market trend was recessive. He, thus, opined that such shares matched all the features of companies which were providing bogus long term capital gains and made additions under section