MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

capital gain. The assessment has been reopened under Section 147 of the Act, by issuing notice under Section 148 dated 29-03-2021, which was presumably served on the assessee in the month of April 2021. The assessment has been completed under Section 147 r.w.s. 144C(13

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

capital gain. The assessment has been reopened under Section 147 of the Act, by issuing notice under Section 148 dated 29-03-2021, which was presumably served on the assessee in the month of April 2021. The assessment has been completed under Section 147 r.w.s. 144C(13

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

capital gain. The assessment has been reopened under Section 147 of the Act, by issuing notice under Section 148 dated 29-03-2021, which was presumably served on the assessee in the month of April 2021. The assessment has been completed under Section 147 r.w.s. 144C(13

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

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

144C(13) of the Income Tax Act, 1961 (for short “the Act”), pertaining to the assessment year 2013-14. 2. The grounds raised by the assessee read as under : “1. Erred in making the ALP adjustment u/s. 92CA(3) of the Act for Rs. 1,16,97,360/- towards Interest 8% on Outstanding Receivables of Rs.14,62,16,997/- from

ORBIS REAL ESTATE FUND I,HYDERABAD (AUTH. REP.) vs. ADIT (INTERNATIONAL TAXATION)-2 - 2, HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

144C(13) of the Act on 30.06.2023 by making addition of Rs.80,00,13,814/- on account of income from capital gain and addition of Rs.83,62,670/- on account of disallowance of expenditure u/s. 40(a)(i) of the Act. 4.2 Aggrieved with the final assessment order of Ld. AO, the assessee is in appeal before

SRUTHI RIEDL,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-2, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Sruthi Riedl, Income Tax Officer, Hyderabad Vs. (International [Pan No. Aggpp6953R] Taxation)-2, Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा /Assessee By: Shri H. Srinivasulu, Ar /Revenue By: Ms. T. Vijaya Lakshmi, Cit-Dr राजस्‍वजस्‍व द्वारा सुनवाई ई की तारीखीख/Date Of Hearing: 28/08/2023 घोषणा की तारीखीख/Pronouncement On: 08/11/2023

sections 50C, 50CA.and 50D.” 2. The brief facts of the case are that assessee being an NRI has filed the return of income for the A.Y. 2016 - 17 declaring an income of Rs.18,26,340/- towards income from house property and towards income from short term and long term capital gains and the case was processed. Thereafter, information was received

DCIT., (INTERNATIONAL TAXATION)-1, HYDERABAD vs. SYAMA REDDY MALI REDDY, HYDERABAD

Section 144C(3) of the Act, dated 30.11.2021,\nredetermined the “Long-Term Capital Gains” (“LTCG") disclosed by\nthe assessee on sale of 25 plots situated at Medipally, Uppal,\nHyderabad, and 4 plots at Bhongir District, at Rs.4,01,68,370/-\nby an amount of Rs.7,58,13

ASRA AHMED ,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

section 56(2)(vii) of the Act, and passed draft assessment order u/s 144C(1) on 31.03.2023, determining total income at Rs.4,11,26,293/-. 4. The assessee has filed objections against draft assessment order before DRP on 28.04.2023 and challenged proposed additions made by the Ld.AO towards computation of long-term capital gains and additions towards cash consideration

SYED AHMED ZEESHANUDDIN,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2 , HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

section 56(2)(vii) of the Act, and passed draft assessment order u/s 144C(1) on 31.03.2023, determining total income at Rs.4,11,26,293/-. 4. The assessee has filed objections against draft assessment order before DRP on 28.04.2023 and challenged proposed additions made by the Ld.AO towards computation of long-term capital gains and additions towards cash consideration

MADHU KUMAR PATEL,HYDERABAD vs. ADIT, ( INT TAXN)-2, HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

section 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (for short “the Act”), consequent to the directions of learned Dispute Resolution Panel, Bengaluru (“learned DRP”), assessee filed this appeal. ITA-IT No. 133/Hyd/2023 2. Brief facts of the case, as pleaded by the assessee are that, the assessee is an individual, an NRI and aged about 89 years

SOMNATH KONDURU,UNITED STATES vs. I.T.O (INT TAXN)-1, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

capital gains. Since the very foundation of reopening of the assessment is collapsed, in our considered view, the subsequent issue of notice under section 148 of the Act and consequent final assessment order passed by the Assessing Officer under section 144 rws 144C(13

RAJU SURYANARAYANA ALLURI,USA vs. ITO (INT TAXN)-1, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

144C(13) of the Act on 14.03.2024 at total income of Rs.42,24,600/-. 4. Aggrieved with the order of Ld. AO, the assessee is in appeal before us. The Learned Authorised Representative (“Ld. AR”) submitted that, the assessee had merely entered into an agreement with the developer and did not receive any consideration neither monetary nor in kind during

CAMBRIDGE TECHNOLOGY ENTERPRISES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.536/Hyd/2019 (निर्धारण वर्ा/Assessment Year: 2012-13) M/S Cambridge Technology Vs. Dcit Enterprises Limited Circle-1(2) Hyderabad Hyderabad [Pan :Aaacu3358G] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri Shiva Sewak, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 28/10/2024 घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.03.2019 Of The Learned Principal Commissioner Of Income Tax [Ld.Pcit], Hyderabad Pertaining To A.Y.2012-13. 2. The Brief Facts Of The Case Are That The Assessee Company, Engaged In The Business Of Rendering Software Services, Filed Its Return Of Income For The A.Y.2012-13 On 26.09.2012, Admitting Total Income Of Rs.4,05,55,380/- Under Normal Provisions Of Income Tax Act, 1961 (“The Act”) & Rs.1,47,09173/-

144C(13) of the Act, because, the Assessing Officer 7 Cambridge Technology Enterprises Limited does not have any power to go beyond the directions issued by the DRP. Therefore, there is no question of the Ld.PCIT, holding that the final assessment order is erroneous so as to come within the ambit of section 263 of the Act. In this regard

MOHSIN HIMMATI,HYDERABAD vs. ADIT(INT TAXN)-1, HYDERABAD

In the result, the appeal of the assessee is allowed

sections": [ "143(3)", "144C(13)", "139(1)" ], "issues": "Whether the payments made by the father for the purchase of the immovable property can be allowed as cost of acquisition for computing long-term capital gains

RAMESH REDDY GONGALLA,UNITED STATES vs. ADIT(INT TAXN)-1, HYDERABAD

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

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

144C(13) of the Income tax Act, 1961 (“the Act”), assessee preferred this appeal. 2. Assessee is an individual. He is nonresident of India and resident of America. He possessed 500 sq.yds of site and he entered into development agreement cum General Power of Attorney on 31/05/2016 along with 45 others in favour of M/s Preston Developers LLP, under which

TEK SYSTEMS GLOBAL SERVICES PRIVATE LIMITED,HYDERBAD vs. DCIT, CIRCLE-2(1), HYDERBAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.487/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2018-19) Tek Systems Global Vs. Dy. C. I. T. Services (P) Ltd, Circle 2(1) Hyderabad Hyderabad Pan:Aabcf1518Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms. K. Amulya, Ca रधजस् व द्वधरध/Revenue By:: Shri Jeevan Lal Lavidiya, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 29/05/2024 घोर्णध की तधरीख/Pronouncement: 05/07/2024 आदेश/Order

144C(5) of the Act, is illegal, thus, making the final assessment order bad in law, null and void and thus, liable to be quashed.” 3. Facts of the case, in brief, are that the assessee TES Systems Global Services (P) Ltd (formerly Frontline Consulting Services P Ltd) was incorporated on Nov. 23, 2007 as per the provisions of software

PANDA SRINIVAS,HYDERABAD vs. ADIT (INT TAXN)-2, HYDERABAD

Bench: Us:

Section 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (for short “the Act”) dated 21.12.2024 for A.Y. 2018-19. The assessee has assailed the impugned order on the following grounds of appeal before us: 3 Panda Srinivas 4 Panda Srinivas 5 Panda Srinivas 6 Panda Srinivas 2. Succinctly stated, the A.O. based on information that the assessee

HIGHRADIUS TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -2(1), HYDERABAD

Bench: Us:

144C(13) r.w.s 144B of the Act, dated 25.02.2024, has carried the matter in appeal before us. 9. We have heard the Ld. Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them to drive home their

PAVAN KUMAR REDDY KADIGARI,USA vs. ITO, (INT TAXN)-2, HYDERABAD

In the result, all the captioned six appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

section 144C(15)(i) as the term “non-resident not being a company” is introduced by the Finance Act 2020 w.e.f 01.04.2020, therefore, the assessment made 17.01.2023 is barred by limitations, therefore, the same is to be held as invalid. 4. The learned Assessing Officer ITO (Int Taxn)-2, being a jurisdictional officer of the assessee has not issued notice