KYORI INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD
In the result, appeal of the assessee is dismissed
ITA 451/HYD/2020[2015-16]Status: DisposedITAT Hyderabad24 Jan 2022AY 2015-16
Bench: S/Shri A .Mohan Alankamony & Chandra Mohan Gargassessment Year : 2015-16 M/S. Kyori Infrastructure Pvt Vs. Dcit, Circle-2(1), Ltd., C/O. P Murali & Co., Ca, Hyderabad 6-3-655/2/3, Samajiguda, Hyderabad Pan/Gir No. (Appellant) .. ( Respondent) Assessee By : Shri P.Murali Mohan Rao, Ar Revenue By : Shri B.Bala Krishna Cit (Dr) Date Of Hearing : 13/10/ 2021 Date Of Pronouncement : 24/01/2022 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order U/S.263 Of The Act Of The Pr. Cit-2, Hyderabad Dated 26.2.2020 For The Assessment Year 2015-16. 2. Facts Of The Case Are That The Assessee Company Is Engaged In The Business Of Construction & Infrastructure Activity. It Filed The Return Of Income For Assessment Year 2015-16 On 30.9.2015 Declaring Total Income At Rs.15,58,050/-. The Case Was Taken Up For Scrutiny & The Assessment Was Completed U/S.143(3) Of The Act On 27.12.2017 With The Assessed Income At Rs.15,58,050/-. P A G E 1 | 11 Assessment Year : 2015-16
For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: Shri B.Bala Krishna CIT (DR)
Section 143(3)Section 263Section 45(2)
section 48, i.e. for the purpose of calculation of capital gains accrued to him from such conversion of capital asset into stock in trade. It has also been provided that for the purpose of calculation of capital gains u/s48 of the Act, the fair market value of the assessee on the date of such conversion or treatment shall be deemed