SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

capital gains arising from the sale of plots out of the same land in its return of income for the relevant assessment year by invoking the deeming provisions of section 50C of the Act. We, thus, in the backdrop of the aforesaid facts, are of a firm conviction that the nexus between the seized material and the assessee’s land

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

capital gains arising from the sale of plots out of the same land in its return of income for the relevant assessment year by invoking the deeming provisions of section 50C of the Act. We, thus, in the backdrop of the aforesaid facts, are of a firm conviction that the nexus between the seized material and the assessee’s land

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

capital gains arising from the sale of plots out of the same land in its return of income for the relevant assessment year by invoking the deeming provisions of section 50C of the Act. We, thus, in the backdrop of the aforesaid facts, are of a firm conviction that the nexus between the seized material and the assessee’s land

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

capital gains arising from the sale of plots out of the same land in its return of income for the relevant assessment year by invoking the deeming provisions of section 50C of the Act. We, thus, in the backdrop of the aforesaid facts, are of a firm conviction that the nexus between the seized material and the assessee’s land

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

Bench: Us:

Capital Gains” (“LTCG") on the sale of the subject property at Rs.2,66,74,645/-. 4. Apart from that, the A.O. made an addition of Rs.1,75,947/- based on the information gathered by him from Insight Portal as the income of the assessee from “Other Sources”. Accordingly, the A.O. vide his draft assessment order u/s 144C

GAJANAN FINANCIAL SERVICES PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. ACIT, CIRCLE-2(3), HYDERABAD, HYDERABAD

Bench: Shri S.S. Godara & Shri L. P. Sahu(Through Virtual Hearing)

3) of the Act but also the issue of appropriate computation of the former head of short term capital gain had nowhere been examined during the course of scrutiny assessment in the first round. We also quote section 147 Expln. 2 that a wrong claim of loss which is not allowable under law had been accepted by the Assessing Officer

KRISHNA KISHORE REDDY MANYAM ,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(4) , HYDERABAD

In the result, the appeal filed by the assessee is partly allowed\nfor statistical purposes in terms of our aforesaid observations

3) of the Income Tax\nAct, 1961 (for short, “the Act”) dated 29.12.2010 for A.Y. 2008-09.\nThe assessee has assailed the impugned order on the following\ngrounds of appeal before us:\n“1. The order of the Hon'ble CIT(A) is erroneous in law as well as facts\nof the case

SRUJITHA ANNAPAREDDY,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-12(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No.253/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Surjitha Annapareddy Vs. Income Tax Officer Secunderabad Ward 12(1) Pan:Bnwpa6703L Hydrabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Y Srikanth Reddy, Dr सुनवाई की तारीख/Date Of Hearing: 22/05/2024 घोषणा की तारीख/Pronouncement: 22/05/2024

capital gains through managed trading of shares. Thus, the whole exercise shows a predetermined mind on the part of the A0 to issue notice under section 148 and complete lack of application of mind on receipt of information from the Investigation Wing without carrying out any further examination/verification and that too at the fag end of the limitation period

ACIT, CENTRAL CIRCLE-2(2) , HYDERABAD vs. LAKSHMI NARAYANA KAZA, , PEDAGONNURU

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

3) terms ascertained with reasonable certainty - yes 4)transferee taken possession of property - yes (third party) 5) transferee has performed or is willing to perform his part of the contract - yes (e ) There is no stipulation in the above provisions of section 53A of the Transfer of Property Act that the possession to the transferee should be directly from

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. KAVYA KAZA, HYDERABAD

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

3) terms ascertained with reasonable certainty - yes 4)transferee taken possession of property - yes (third party) 5) transferee has performed or is willing to perform his part of the contract - yes (e ) There is no stipulation in the above provisions of section 53A of the Transfer of Property Act that the possession to the transferee should be directly from

REVANTH REDDY ANUMALA,BANJARA HILLS vs. A.C.I.T CENTRAL CIRCLE-1(2), HYDERABAD

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed in the section has also been used identically in sub- section 3 of section

KAKINADA INFRASTRUCTURE HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

capital gains of Rs.373 crores\non account of sale of shares of Kakinada Seaports Limited to\nM/s. Auro Infra Private Limited. Since, this was the income\noffered by the assessee and accepted by the Assessing Officer\nand therefore, there was no question of dispute on this point\nat the stage of assessment order as well as appellate order\npassed

PAYAL JINDAL ,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

In the result, the appeals of both the assessees are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

Capital Gain was offered in Return of Income ignoring the fact that the property was sold for the same price for which it was purchased and as result no gain or loss arose. 7) That the learned CIT(Appeals) erred in confirming the action of Assessing Officer of taking value fixed by Registration Authority for Stamp Duty as full value

RAJKUMAR JINDAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

In the result, the appeals of both the assessees are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

Capital Gain was offered in Return of Income ignoring the fact that the property was sold for the same price for which it was purchased and as result no gain or loss arose. 7) That the learned CIT(Appeals) erred in confirming the action of Assessing Officer of taking value fixed by Registration Authority for Stamp Duty as full value

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

capital gains tax: It is an undisputed position that respondent assessee is an investment company and had invested by purchasing a substantial number of shares and thereby securing right to management. Possibility of sale of shares by private placement etc. cannot be ruled out and is not all improbability. Dividend may or may not be declared. Dividend is declared

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

capital gains tax: It\nis an undisputed position that respondent assessee is an investment company\nand had invested by purchasing a substantial number of shares and thereby\nsecuring right to management. Possibility of sale of shares by private\nplacement etc. cannot be ruled out and is not all improbability. Dividend may or\nmay not be declared. Dividend is declared

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/- in its books of account and claiming the deduction u/s 36(1)(vii) of the Act. Hence he prayed that the actual amount of debt written off by the assessee after reducing the amount received from government under ADWDRS should be allowed as deduction u/s 36(1)(vii) of the Act. 6.4 Per contra, the Ld. DR placed heavy

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/- in its books of account and claiming the deduction u/s 36(1)(vii) of the Act. Hence he prayed that the actual amount of debt written off by the assessee after reducing the amount received from government under ADWDRS should be allowed as deduction u/s 36(1)(vii) of the Act. 6.4 Per contra, the Ld. DR placed heavy

THE ANDHRA PRADESH STATE CO OPERATIVE BANK LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

253/- in its books of account and claiming the deduction u/s 36(1)(vii) of the Act. Hence he prayed that the actual amount of debt written off by the assessee after reducing the amount received from government under ADWDRS should be allowed as deduction u/s 36(1)(vii) of the Act. 6.4 Per contra, the Ld. DR placed heavy