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)

Section 144C(13) dated 08.01.2024 is barred by limitation and is liable to be quashed and thus, we quash the re-assessment order passed by the Assessing Officer u/s 147 r.w.s. 144C(13) of the Act dt.08.01.2024 for the A.Y. 2016-17. 20. The assessee has argued the issue of addition made towards capital gain from sale of property

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)

Section 144C(13) dated 08.01.2024 is barred by limitation and is liable to be quashed and thus, we quash the re-assessment order passed by the Assessing Officer u/s 147 r.w.s. 144C(13) of the Act dt.08.01.2024 for the A.Y. 2016-17. 20. The assessee has argued the issue of addition made towards capital gain from sale of property

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)

Section 144C(13) dated 08.01.2024 is barred by limitation and is liable to be quashed and thus, we quash the re-assessment order passed by the Assessing Officer u/s 147 r.w.s. 144C(13) of the Act dt.08.01.2024 for the A.Y. 2016-17. 20. The assessee has argued the issue of addition made towards capital gain from sale of property

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

ITO (INTERNATIONAL TAXATION)-1, HYDERAABAD vs. DEENABABU KONDUBHATLA, HYDERABAD

Bench: Us :

Gains (for short “STCG”) on the transfer of the same at Rs.2,15,25,000/-. The A.O., vide his order passed under Section 143(3) r.w.s. 144C(3) of the Act, dated 24.05.2024, made an addition of short-term capital

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

3) r.w.s. 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

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

144C of the Act, assessing the total income at Rs. 8,09,06,331/-. He proposed addition of Rs. 1,32,01,339/- on account of short-term capital gains, and Rs. 6,77,04,992/- on account of long-term capital gains by way of disallowance of claim of section 54F of the Act already granted by learned

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, purchase deed and sale deed copies, valuation report and other documentary evidences. The Assessing Officer after considering relevant evidences filed by the assessee, has completed the assessment under section 144C and has 3

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)

capital gains and additions towards cash consideration u/s 56(2)(vii) of the Act. The DRP, vide directions issued u/s 144C(5) of the Act on 26/12/2023, rejected the objections filed by the assessee and upheld the additions proposed by the Ld.AO. Thereafter, the Ld.AO passed final assessment order u/s 153C r.w.s.144C(13) of the Act, on 19/01/2024 and determined

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)

capital gains and additions towards cash consideration u/s 56(2)(vii) of the Act. The DRP, vide directions issued u/s 144C(5) of the Act on 26/12/2023, rejected the objections filed by the assessee and upheld the additions proposed by the Ld.AO. Thereafter, the Ld.AO passed final assessment order u/s 153C r.w.s.144C(13) of the Act, on 19/01/2024 and determined

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

3. The brief facts of the case are that, the assessee is a non-resident individual, had not filed any Return of Income (“ROI”) u/s.139 of the Act. From the available record, the Learned Assessing Officer (“Ld. AO") came to know that the assessee along with five other co-owners entered into Joint Development Agreement (“JDA”) on 27.11.2015 with

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

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

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year:2015-16 Shri Madhu Kumar Patel Vs. A.D.I.T (Intl.Taxation)-2 Hyderabad Hyderabad Pan:Bvdpp3797G (Appellant) (Respondent) Assessee By: Shri K.A. Sai Prasad, Ca Revenue By: Shri Rajendra Kumar, Cit(Dr) Date Of Hearing: 10/11/2022 Date Of Pronouncement: 26/12/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.7.2022 Passed U/S 147 R.W.S. 144C(13) Of The I.T. Act For The A.Y 2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & A Resident Of The U.K. He Filed His Return Of Income On 31.08.2015 Declaring Total Income At Rs.2,91,07,000/- As Income From Long Term Capital Gain.

144C(13) of the I.T. Act for the A.Y 2015-16. 2. Facts of the case, in brief, are that the assessee is an individual and a resident of the U.K. He filed his return of income on 31.08.2015 declaring total income at Rs.2,91,07,000/- as income from Long Term Capital Gain. 3. In this case, information

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

144C(3) and 144B was passed by the Learned Assessing Officer (“Ld. AO”) on 28.06.2021, making an addition of Rs.2,26,82,071/- on account of transfer pricing adjustment. 4. Thereafter, the Ld. PCIT invoked provisions of section 263 of the Act and issued notice to the assessee on 08.03.2024. The Ld. PCIT recorded that the Ld. AO during scrutiny

NAVEEN KUMAR MUSINIPALLY,USA vs. ADIT (INT-TAXN)-1, HYDERABAD

Bench: Shri Manjunatha G & Shri Ravish Sood

capital gains arising on the development agreement under Section 153C r.w.s 144C(3) of the Income Tax Act 1961 ('the Act') in the subject

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

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

ADP PRIVATE LIMITED,RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

In the result, both the appeals are partly allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

144C(13) read with sections 143(3A) & 143(3B) of the Act on the following grounds: General: 1. On the facts and circumstances of the case and in contrary to law, the Additional Commissioner of Income-tax (Transfer Pricing), (hereinafter referred to as 'the Ld. TPO') and the Ld. AO under the directions issued by the Hon'ble Dispute Resolution