BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

capital gain, under the facts and circumstances of the case. 10. The Appellant denies himself liable to interest under section 234A, 2348 and 234C of the Act, under the facts and circumstances of the case. 11. The Appellant craves leave to add, alter, delete or substitute any of the grounds urged above. 4 ITA.No.1527 & 1528/Hyd./2025

INCOME TAX OFFICER, WARD 3(1), HYDERABAD vs. STYPACK PRIVATE LIMITED , HYDERABAD

In the result, the appeal of the revenue is dismissed, while the cross-objection of the assessee company is allowed in terms of our aforesaid observations

Bench: Us:

Section 147 r.w.s.144B of the Income Tax Act, 1961 (for short “the Act”) dated 21.03.2024 for A.Y. 2018-19. The revenue has assailed the impugned order on the following grounds of appeal before us: 3 ITA No.997/Viz/2024 & CO No.27/Hyd/2024 Stypack Private Limited 2. Apart from that, the assessee company is before us as a cross- objector on the following grounds

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

capital gain of Rs. 2,56,90,030 was wrongly taxed in AN 201647. 4. The Id A.O/DRP failed to appreciate that the physical possession of land under the Joint Development Agreement (JDA) dated 04/04/2007 was given in F.Y 2007-08 to the developer and the second JDA dated 10.02.2016 is in continuation of the JDA dated

ABHISHEK REDDY BOYAPALLY,HYDERABAD vs. ITO (INT TAXN) - 2, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.352/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2015-16) Shri Abhishek Reddy Vs. Income Tax Officer Boyapally, Hyderabad International Taxation-2, Pan: Bodpb0397F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ca Y. V. Bhanu Narayan Rao रधजस् व द्वधरध/Revenue By: Dr.Narendra Kumar Naik, Cit(Dr) सुिवधई की तधरीख/Date Of Hearing: 15/10/2025 घोर्णध की तधरीख/Pronouncement: 17/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Abhishek Reddy Boyapally (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Ito, International Taxation-2, Hyderabad (“Ld. Ao”), Dated 25.12.2024 For The A.Y 2015-16. 2. The Assessee Has Raised The Following Grounds Of Appeal:

148A(d) of the Act on the same date. After considering the submission of the assessee the Ld. AO passed draft order under section 144C of the Act proposing addition of Rs.1,892/- under income from other sources and Rs.37,21,500/- towards Short Term Capital Gain

RAZIULLA SYED,HYDERABAD vs. ITO (INT TAXN)-2, HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Section 148A prescribing the procedure for reopening and reassessment proceedings. In pursuance to the Judgment of the Hon’ble Supreme Court the CBDT vide it’s instruction No.1/2022 dated 11.05.2022, 5 ITA.No.986/Hyd./2024 directed the Assessing Officers to pass on the benefit of new law shall be made available even in respect of proceedings relating to past assessment years

SRINIVAS PAMPATI,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-2, KARIMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

capital gains on transfer of immovable property of Rs.1,71,13,333/-. Accordingly, the Ld. AO reopened the case of the assessee under section 147 of the Income Tax Act, 1961 (“the Act”). After passing order under section 148A

MAMATHA GUBBALA,HYDERABAD vs. ITO., WARD-15(1), HYDERABAD

capital gains.", "held": "The Tribunal set aside the order of the CIT(A) and restored the matter to the CIT(A)'s file. The direction was to adjudicate the specific grounds of appeal concerning the validity of the jurisdiction assumed by the AO for framing the reassessment order.", "result": "Partly Allowed", "sections": ["Section 147", "Section 144", "Section 148A

KATRAPALLY VENUMADHAV,WARANGAL vs. INCOME TAX OFFICER, WARD-4(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

148A(d) of the Act was passed on 28/04/2022. Thereafter, the AO issued notice under section 148 of the Act, dated 28/04/2022. 4. Thereafter, the AO vide his order under section 147 r.w.s 144 r.w.s 144B of the Act, dated 08/02/2024, determined the income of the assessee at Rs.66,20,660/- after making certain additions, viz., (i) addition of salary

KATRAPALLY VENUMADHAV,WARANGAL vs. INCOME TAX OFFICER, WARD-4(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

148A(d) of the Act was passed on 28/04/2022. Thereafter, the AO issued notice under section 148 of the Act, dated 28/04/2022. 4. Thereafter, the AO vide his order under section 147 r.w.s 144 r.w.s 144B of the Act, dated 08/02/2024, determined the income of the assessee at Rs.66,20,660/- after making certain additions, viz., (i) addition of salary

HANMANDLU PAMPATI,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-2, KARIMNAGAR

The appeal of the assessee is allowed

capital gains on transfer of immovable property of\nRs.1,71,13,333/-. Accordingly, the Ld. AO reopened the case of the\nassessee under section 147 of the Income Tax Act, 1961 (“the Act”).\nAfter passing order under section 148A

SUDHAKER MUNIGETI,ADILABAD vs. ITO., WARD-1, ADILABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.471/Hyd/2025 Assessment Years – 2019-2020 Sudhaker Munigeti, The Income Tax Officer, Vs. Adilabad – 504 001. Ward-1, Telangana. Adilabad. Pan Acapm9247K Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca, A Srinivas राज" व "ारा /Revenue By: Ms Malathi B. Sr. Ar

section 143(2) differ on the nature of income escaping assessment, and as such has been issued without application of mind and needs to be quashed 8. Without prejudice to the above grounds, the Appellate Commissioner erred in confirming the addition of an amount of Rs.36,03,333/-, being long term capital gain. 9. Any other grounds which the Assessee

NISHA KAPISTALAMCHETLUR,TIRUPATI vs. ITO, WARD-1(1), TIRUPATI

148A and sanction under the new Section 151 and in the absence of such compliance the notice is invalid and the reassessment proceedings are void. 4. The reassessment notices for A.Y. 2013-14 under section 148, though dated 31.03.2021, was issued only on 01.04.2021 ie., beyond three years, without proper sanction under section 151 (ii) of the amended

NISHA KAPISTALAMCHETLUR,TIRUPATI vs. ITO, WARD-1(1), TIRUPATI

148A and sanction under the new Section 151 and in the absence of such compliance the notice is invalid and the reassessment proceedings are void. 4. The reassessment notices for A.Y. 2013-14 under section 148, though dated 31.03.2021, was issued only on 01.04.2021 ie., beyond three years, without proper sanction under section 151 (ii) of the amended

ACIT., CIRCLE-8(1), HYDERABAD vs. RAJIV GUPTA, HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.278/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Assistant Commissioner Of Vs. Rajiv Gupta, Income Tax, Hyderabad. Cirle-8(1), Hyderabad. Pan: Acapg4029K (Appellant) (Respondent)

Gains (LTCG)/Short Term Capital Loss (STCL) on penny stocks. Accordingly, the Ld. Sr. DR submitted that the CIT(A) had erred in observing that the AO had wrongly assumed jurisdiction and issued the notice under section 148 of the Act, dated 30/07/2022 beyond the period of three years from the end of the relevant assessment year. 8. Per contra

PRAJYOTH KUMAR ADI,HYDERABAD vs. ITO, WARD-4(1), HYDERABAD

In the result, both the appeals filed by the assessee are allowed for statistical purposes in terms of our aforesaid observations

Bench: us: “1. On the facts and in the circumstances of the case, the order of the Id. CIT(A) is erroneous both on facts and in law, and is passed in gross violations of principles of natural justice.

148A(d) of the Act, dated 11/03/2024. Notice under section Prajyoth Kumar Adi vs. ITO 148 of the Act, dated 12/03/2024 was issued to the assessee. However, the assessee failed to file his return of income in compliance to the notice issued under section 148 of the Act. Also, the notices issued by the AO under section

MAHESH KUMAR BHATI,HYDERABAD vs. ITO, WARD 7(1), HYDERABAD

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

Bench: transfer making it a long term capital asset whereas the A.O. has treated the same as short term capital asset. 4. The assessment made by learned A.O. and upheld by the CIT(A) is incorrect as while computing capital gains indexed cost of acquisition has not been considered leading to excess assessment. 7. For these and other ground which may be raised during OR before the

section 250. 2. The learned CIT(A) erred in dismissing the appeal for non-prosecution ignoring that CIT(A) has to adjudicate and dispose off the appeal on merits and has no power to dismiss the appeal in limine for want of prosecution. 3. The assessment made by learned A.O. and upheld by the CIT(A) is incorrect

PRAJYOTH KUMAR ADI,HYDERABAD vs. ITO, WARD-4(1), HYDERABAD

In the result, both the appeals filed by the assessee are allowed for\nstatistical purposes in terms of our aforesaid observations

148A(d) of the Act, dated 11/03/2024. Notice under section\n148 of the Act, dated 12/03/2024 was issued to the assessee. However,\nthe assessee failed to file his return of income in compliance to the notice\nissued under section 148 of the Act. Also, the notices issued by the AO\nunder section 142(1) of the Act, dated 01/08/2024

RONAK GUPTA,HYDERABAD vs. ACIT., CENTRAL CIRCLE -3(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.965/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Ronak Gupta Vs. Asstt. Cit Hyderabad Circle 3(1) Pan:Aiapg3319G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. Siddharth Toshnival राज" व "ारा/Revenue By:: Shri Ranjan Agarwala, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Ronak Gupta (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad (“Ld. Cit(A)”) Dated 30.03.2025 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

capital gains and income Page 2 of 7 ITA No 965 of 2025 Ronak Gupta from other sources. The assessee filed his return of income for the Assessment Year 2016–17 on 17.10.2016, declaring total income of Rs.39,89,130/-. The return of the assessee was processed under section 143(1) of the Income Tax Act, 1961 (“the Act”). Subsequently