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

section 11(6) of the Act is prospective in nature and will be applicable w.e.f. A.Y. 2015- ITA No.29/Hyd/2024 7 16. Hence respectfully relying on the decision of the Hon’ble Supreme Court in the case of Commissioner of Income Tax v/s Rajasthan and Gujarati Charitable Foundation Poona(Supra), we hold that in the case of the assessee the provisions

SAJJAN RAJ JAIN (HUF),HYDERABAD vs. ACIT CENTRAL CIRCLE-1 (2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R. K. Pandaappeal In Assessee Department A.Y Ita No 188/Hyd/2022 Smt.Sunita Devi, Hyderabad Acit, Central Circle 2016-17 Pan:Adppd6447C 1(2) Hyderabad 189/Hyd/2022 -Do- -Do- 2017-18 190/Hyd/2022 Smt.Anita Jain, Hyderabad -Do- 2016-17 Pan:Abjpj1532C 191/Hyd/2022 Smt.Premalata, Hyderabad -Do- 2016-17 Pan:Acupp5966A 192/Hyd/2022 Sh. Prakash Chand Jain -Do- 2016-17 (Huf) Hyderabad Pan:Aadhp6992D 194/Hyd/2022 Shri Sajjan Raj Jain (Huf) -Do- 2016-17 Hyderabad Pan:Aaghs6338K 195/Hyd/2022 Sh.Sajjanraj Jain & Wife -Do- -Do- (Huf) Hyderabad

purchased 30, 000 shares of M/s. Jackson Investments Ltd at Rs.10/- each per share through M/s. Badri Prasad & Sons (Stock Exchange Broker) on 23.04.2014. Thereafter, the face value of the shares was brought down to Rs.1/- per share from Rs.10/- and the assessee sold 70,000 shares through M/s. Axis Securities Ltd and received an amount of Rs.8

SUNITA DEVI,HYDERABAD vs. ACIT CENTRAL CIRCLE-1 (2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R. K. Pandaappeal In Assessee Department A.Y Ita No 188/Hyd/2022 Smt.Sunita Devi, Hyderabad Acit, Central Circle 2016-17 Pan:Adppd6447C 1(2) Hyderabad 189/Hyd/2022 -Do- -Do- 2017-18 190/Hyd/2022 Smt.Anita Jain, Hyderabad -Do- 2016-17 Pan:Abjpj1532C 191/Hyd/2022 Smt.Premalata, Hyderabad -Do- 2016-17 Pan:Acupp5966A 192/Hyd/2022 Sh. Prakash Chand Jain -Do- 2016-17 (Huf) Hyderabad Pan:Aadhp6992D 194/Hyd/2022 Shri Sajjan Raj Jain (Huf) -Do- 2016-17 Hyderabad Pan:Aaghs6338K 195/Hyd/2022 Sh.Sajjanraj Jain & Wife -Do- -Do- (Huf) Hyderabad

purchased 30, 000 shares of M/s. Jackson Investments Ltd at Rs.10/- each per share through M/s. Badri Prasad & Sons (Stock Exchange Broker) on 23.04.2014. Thereafter, the face value of the shares was brought down to Rs.1/- per share from Rs.10/- and the assessee sold 70,000 shares through M/s. Axis Securities Ltd and received an amount of Rs.8

SAJJANRAJ JAIN & WIFE (HUF),HYDERABAD vs. ACIT CENTRAL CIRCLE-1 (2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R. K. Pandaappeal In Assessee Department A.Y Ita No 188/Hyd/2022 Smt.Sunita Devi, Hyderabad Acit, Central Circle 2016-17 Pan:Adppd6447C 1(2) Hyderabad 189/Hyd/2022 -Do- -Do- 2017-18 190/Hyd/2022 Smt.Anita Jain, Hyderabad -Do- 2016-17 Pan:Abjpj1532C 191/Hyd/2022 Smt.Premalata, Hyderabad -Do- 2016-17 Pan:Acupp5966A 192/Hyd/2022 Sh. Prakash Chand Jain -Do- 2016-17 (Huf) Hyderabad Pan:Aadhp6992D 194/Hyd/2022 Shri Sajjan Raj Jain (Huf) -Do- 2016-17 Hyderabad Pan:Aaghs6338K 195/Hyd/2022 Sh.Sajjanraj Jain & Wife -Do- -Do- (Huf) Hyderabad

purchased 30, 000 shares of M/s. Jackson Investments Ltd at Rs.10/- each per share through M/s. Badri Prasad & Sons (Stock Exchange Broker) on 23.04.2014. Thereafter, the face value of the shares was brought down to Rs.1/- per share from Rs.10/- and the assessee sold 70,000 shares through M/s. Axis Securities Ltd and received an amount of Rs.8

SUNITA DEVI,HYDERABAD vs. ACIT CENTRAL CIRCLE-1 (2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R. K. Pandaappeal In Assessee Department A.Y Ita No 188/Hyd/2022 Smt.Sunita Devi, Hyderabad Acit, Central Circle 2016-17 Pan:Adppd6447C 1(2) Hyderabad 189/Hyd/2022 -Do- -Do- 2017-18 190/Hyd/2022 Smt.Anita Jain, Hyderabad -Do- 2016-17 Pan:Abjpj1532C 191/Hyd/2022 Smt.Premalata, Hyderabad -Do- 2016-17 Pan:Acupp5966A 192/Hyd/2022 Sh. Prakash Chand Jain -Do- 2016-17 (Huf) Hyderabad Pan:Aadhp6992D 194/Hyd/2022 Shri Sajjan Raj Jain (Huf) -Do- 2016-17 Hyderabad Pan:Aaghs6338K 195/Hyd/2022 Sh.Sajjanraj Jain & Wife -Do- -Do- (Huf) Hyderabad

purchased 30, 000 shares of M/s. Jackson Investments Ltd at Rs.10/- each per share through M/s. Badri Prasad & Sons (Stock Exchange Broker) on 23.04.2014. Thereafter, the face value of the shares was brought down to Rs.1/- per share from Rs.10/- and the assessee sold 70,000 shares through M/s. Axis Securities Ltd and received an amount of Rs.8

PRAKASH CHAND JAIN(HUF),HYDERABAD vs. ACIT CENTRAL CIRCLE-1 (2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R. K. Pandaappeal In Assessee Department A.Y Ita No 188/Hyd/2022 Smt.Sunita Devi, Hyderabad Acit, Central Circle 2016-17 Pan:Adppd6447C 1(2) Hyderabad 189/Hyd/2022 -Do- -Do- 2017-18 190/Hyd/2022 Smt.Anita Jain, Hyderabad -Do- 2016-17 Pan:Abjpj1532C 191/Hyd/2022 Smt.Premalata, Hyderabad -Do- 2016-17 Pan:Acupp5966A 192/Hyd/2022 Sh. Prakash Chand Jain -Do- 2016-17 (Huf) Hyderabad Pan:Aadhp6992D 194/Hyd/2022 Shri Sajjan Raj Jain (Huf) -Do- 2016-17 Hyderabad Pan:Aaghs6338K 195/Hyd/2022 Sh.Sajjanraj Jain & Wife -Do- -Do- (Huf) Hyderabad

purchased 30, 000 shares of M/s. Jackson Investments Ltd at Rs.10/- each per share through M/s. Badri Prasad & Sons (Stock Exchange Broker) on 23.04.2014. Thereafter, the face value of the shares was brought down to Rs.1/- per share from Rs.10/- and the assessee sold 70,000 shares through M/s. Axis Securities Ltd and received an amount of Rs.8

PREMLATA,HYDERABAD vs. ACIT CENTRAL CIRCLE-1 (2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R. K. Pandaappeal In Assessee Department A.Y Ita No 188/Hyd/2022 Smt.Sunita Devi, Hyderabad Acit, Central Circle 2016-17 Pan:Adppd6447C 1(2) Hyderabad 189/Hyd/2022 -Do- -Do- 2017-18 190/Hyd/2022 Smt.Anita Jain, Hyderabad -Do- 2016-17 Pan:Abjpj1532C 191/Hyd/2022 Smt.Premalata, Hyderabad -Do- 2016-17 Pan:Acupp5966A 192/Hyd/2022 Sh. Prakash Chand Jain -Do- 2016-17 (Huf) Hyderabad Pan:Aadhp6992D 194/Hyd/2022 Shri Sajjan Raj Jain (Huf) -Do- 2016-17 Hyderabad Pan:Aaghs6338K 195/Hyd/2022 Sh.Sajjanraj Jain & Wife -Do- -Do- (Huf) Hyderabad

purchased 30, 000 shares of M/s. Jackson Investments Ltd at Rs.10/- each per share through M/s. Badri Prasad & Sons (Stock Exchange Broker) on 23.04.2014. Thereafter, the face value of the shares was brought down to Rs.1/- per share from Rs.10/- and the assessee sold 70,000 shares through M/s. Axis Securities Ltd and received an amount of Rs.8

ANITA JAIN,HYDERABAD vs. ACIT CENTRAL CIRCLE-1 (2), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri R. K. Pandaappeal In Assessee Department A.Y Ita No 188/Hyd/2022 Smt.Sunita Devi, Hyderabad Acit, Central Circle 2016-17 Pan:Adppd6447C 1(2) Hyderabad 189/Hyd/2022 -Do- -Do- 2017-18 190/Hyd/2022 Smt.Anita Jain, Hyderabad -Do- 2016-17 Pan:Abjpj1532C 191/Hyd/2022 Smt.Premalata, Hyderabad -Do- 2016-17 Pan:Acupp5966A 192/Hyd/2022 Sh. Prakash Chand Jain -Do- 2016-17 (Huf) Hyderabad Pan:Aadhp6992D 194/Hyd/2022 Shri Sajjan Raj Jain (Huf) -Do- 2016-17 Hyderabad Pan:Aaghs6338K 195/Hyd/2022 Sh.Sajjanraj Jain & Wife -Do- -Do- (Huf) Hyderabad

purchased 30, 000 shares of M/s. Jackson Investments Ltd at Rs.10/- each per share through M/s. Badri Prasad & Sons (Stock Exchange Broker) on 23.04.2014. Thereafter, the face value of the shares was brought down to Rs.1/- per share from Rs.10/- and the assessee sold 70,000 shares through M/s. Axis Securities Ltd and received an amount of Rs.8

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

purchases/ unexplained & unverifiable expenses, as applicable to various vendors as noticed during the search and survey proceedings conducted in the group cases. 4. The Id CIT(A) erred in not following the principle laid down by the jurisdictional High Court of Andhra Pradesh in the case of Gopal Lal Bhadruka vs DCIT 346 ITR 106, wherein it has held that

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

purchases/ unexplained & unverifiable expenses, as applicable to various vendors as noticed during the search and survey proceedings conducted in the group cases. 4. The Id CIT(A) erred in not following the principle laid down by the jurisdictional High Court of Andhra Pradesh in the case of Gopal Lal Bhadruka vs DCIT 346 ITR 106, wherein it has held that

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

purchases/ unexplained & unverifiable expenses, as applicable to various vendors as noticed during the search and survey proceedings conducted in the group cases. 4. The Id CIT(A) erred in not following the principle laid down by the jurisdictional High Court of Andhra Pradesh in the case of Gopal Lal Bhadruka vs DCIT 346 ITR 106, wherein it has held that

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

purchases/ unexplained & unverifiable expenses, as applicable to various vendors as noticed during the search and survey proceedings conducted in the group cases. 4. The Id CIT(A) erred in not following the principle laid down by the jurisdictional High Court of Andhra Pradesh in the case of Gopal Lal Bhadruka vs DCIT 346 ITR 106, wherein it has held that

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

purchases/ unexplained & unverifiable expenses, as applicable to various vendors as noticed during the search and survey proceedings conducted in the group cases. 4. The Id CIT(A) erred in not following the principle laid down by the jurisdictional High Court of Andhra Pradesh in the case of Gopal Lal Bhadruka vs DCIT 346 ITR 106, wherein it has held that

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

purchases/ unexplained & unverifiable expenses, as applicable to various vendors as noticed during the search and survey proceedings conducted in the group cases. 4. The Id CIT(A) erred in not following the principle laid down by the jurisdictional High Court of Andhra Pradesh in the case of Gopal Lal Bhadruka vs DCIT 346 ITR 106, wherein it has held that

K & R RAIL ENGINEERING LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same. Thus, not allowing the eligible TDS credits, Advance Tax and Self Assessment Tax paid is incorrect as the addition pertaining to the reason to believe was not made. 3 K & R Rail Engineering Limited

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same. Thus, not allowing the eligible TDS credits, Advance Tax and Self Assessment Tax paid is incorrect as the addition pertaining to the reason to believe was not made. 3 K & R Rail Engineering Limited

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same. Thus, not allowing the eligible TDS credits, Advance Tax and Self Assessment Tax paid is incorrect as the addition pertaining to the reason to believe was not made. 3 K & R Rail Engineering Limited

K & R RAIL ENGINEERING LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same. Thus, not allowing the eligible TDS credits, Advance Tax and Self Assessment Tax paid is incorrect as the addition pertaining to the reason to believe was not made. 3 K & R Rail Engineering Limited

K & R RAIL ENGINEERING LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(4), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same. Thus, not allowing the eligible TDS credits, Advance Tax and Self Assessment Tax paid is incorrect as the addition pertaining to the reason to believe was not made. 3 K & R Rail Engineering Limited