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12 results for “condonation of delay”+ Deemed Dividendclear

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Key Topics

Section 143(3)15Section 14A9Section 2639Addition to Income7Section 80P(2)(a)6Section 80P6Limitation/Time-bar6Deduction4Disallowance

RAVINDER RAO TAKKALLAPELLY,HYDERABAD vs. DCIT., CIRCLE-1, KARIMNAGAR

In the result, the appeal is allowed for statistical purposes

ITA 477/HYD/2025[2015-16]Status: DisposedITAT Hyderabad18 Jun 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri A. Chiranjeevi, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 147Section 148Section 2(22)(e)

deemed dividend by attributing accumulated profits of Rs.55,37,703 to the shareholder's shareholding percentage was done arbitrarily without substantiating the link between the loan and the distribution of profits. And without looking in to the facts of profits, arbitrarily profits was arrived as Rs.55,37,703. And further there is clear arithmetical error in calculation. The AO Considered

RAMA DEVI TUMMALA,HYDERABAD vs. ACIT., CIRCLE-6(1), HYDERABAD

4
Condonation of Delay4
Section 143(2)3
Section 142(1)3

In the result, the appeal of the assessee is allowed

ITA 778/HYD/2024[2018-19]Status: DisposedITAT Hyderabad05 May 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri T. Chaitanya KumarFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 2(22)(e)Section 263

deemed dividend. The PCIT failed to appreciate that the payments were made for legitimate business expenses of the company, not as loans or advances. 4. The PCIT's findings that the original assessment order was erroneous and prejudicial to the interests of the Revenue are arbitrary, perverse, and based on mere conjectures and surmises. The original assessment was completed after

SEVEN ENERGIES ODISHA LIMITED,HYDERABAD vs. ACIT CIRCLE 3(1), HYD, HYDERABAD

ITA 1518/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1518/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Seven Energies Odisha Vs. Acit, Limited, Circle-3(1), Hyderabad. Hyderabad. Pan: Aatcs5759E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sashank Dundu, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 05/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 07/02/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 18/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee

For Appellant: Shri Sashank DunduFor Respondent: Ms. Aditi Goyal, Sr.AR
Section 143(3)Section 69

condone the delay involved in the filing of the present appeal. 11. Coming to the merits of the case, the Ld. AR has assailed the validity of the order passed by the AO under section 143(3) of the Act, dated 18/12/2018 for two fold reasons, viz., (i) that the AO had exceeded 9 Seven Energies Odisha Limited vs. ACIT

GACM TECHNOLOGIES LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-3(4), HYDERABAD

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

ITA 517/HYD/2024[2017-18]Status: DisposedITAT Hyderabad06 Sept 2024AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year – 2017-18 Gacm Technologies Ltd. Vs. Income Tax Officer Ward-3(4), Hyderabad (Formerly Known As Stampede Capital Limited) Hyderabad Pan : Aaacb7421K (Appellant) (Respondent) Assessee By: Shri Rajesh Vaishnav, Ld.Ar Revenue By: Shri Srinath Sadanala, Ld.Dr 05.09.2024 Date Of Hearing: Date Of Pronouncement: 06.09.2024

For Appellant: Shri Rajesh Vaishnav, Ld.ARFor Respondent: Shri Srinath Sadanala, Ld.DR
Section 14ASection 249(2)Section 249(3)Section 5

dividend earned is exempt income the hands of appellant. 6. The appellant may add, alter or modify any other point to the Grounds of appeal at any time before or at the time of hearing of the appeal. 3. In the present case, at the outset, the Ld.AR submitted that there is a delay of 40 days in filing

THE INDUR INTIDEEPAM PRODUCERS MA CO-OP SOCIETIES FEDERATION LIMITED,NIZAMABAD vs. ITO WARD-1, NIZAMABAD

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

ITA 339/HYD/2023[2017-18]Status: DisposedITAT Hyderabad17 Oct 2023AY 2017-18

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

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Shri Shakeer Ahmed, Sr. A.R
Section 142(1)Section 143(2)Section 143(3)Section 80PSection 80P(2)

delay in filing this appeal is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Case is now taken up for adjudication on merits. 3. The grounds raised by the assessee read as under : “1) The order of the learned CIT (A) is erroneous both on facts and in law. 2) The learned

STATE BANK OF INDIA STAFF CO-OPERATIVE CREDIT SOCIETY LTD,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the assessee is allowed

ITA 667/HYD/2023[2018-19]Status: DisposedITAT Hyderabad09 Feb 2024AY 2018-19

Bench: Shri Inturi Rama Rao & Shri K.Narasimha Chary

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri Shakeer Ahamed, DR
Section 143(1)Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

condone the delay and proceed to hear the matter on merits. 3. Brief facts of the case are that the assessee is registered as a co- operative society, formed by the employees of the SBI Bank Staff. It filed the return of income for the assessment year 2018-19 on 26/09/2018 declaring total income as NIL. Return of income

SREE KANYAKA MUTUALLY AIDED CO-OP THRIFT CREDIT AND MARKETG. SOCIETY LIMITED,HINDUPUR vs. INCOME TAX OFFICER, WARD 1, HINDUPUR

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

ITA 224/HYD/2024[2018-19]Status: DisposedITAT Hyderabad22 Jul 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia

For Appellant: Shri D. Shree Raksha, CAFor Respondent: Shri Shakeer Ahamed, DR
Section 143(3)Section 56Section 80PSection 80P(2)(a)

condone the delay and admit the appeal for hearing. ITA No.224/Hyd/2024 for A.Y. 2018-19 5. Facts of the case, in brief, are that the assessee is a Co- op Society which is carrying on the business of banking and providing credit facilities to its members, which is registered under the Andhra Pradesh Mutually Aided Co-operative Societies

NCL HOMES LIMITED,HYDERABAD vs. ITO WARD-16(1), HYDERABAD

In the result, appeal of the assessee is dismissed

ITA 136/HYD/2022[2016-17]Status: DisposedITAT Hyderabad10 Aug 2022AY 2016-17

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

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR
Section 10Section 143(3)Section 14ASection 263

dividend income of Rs. 26,29,981/- which is exempt under section 10 (34) of the Act and claimed interest expenditure of Rs. 5,72,80,691/- which was debited to the P&L account, but no disallowance was made either in the computation of total income or in the assessment order under section 14A of the Act read with

ANDHRA CARDIOLOGY ASSOCIATES PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(2), HYDERABAD

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

ITA 142/HYD/2018[2013-14]Status: DisposedITAT Hyderabad11 Dec 2023AY 2013-14

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

For Appellant: Shri G.B.S. Maitreya, C.AFor Respondent: Shri Shakeer Ahmed, Sr. A.R
Section 143(2)Section 143(3)Section 14ASection 194ASection 194CSection 234BSection 234CSection 40

condone the delay and admit the appeal for hearing. 3. The grounds raised by the assessee read as under : “1) The order of the learned Commissioner of Income-Tax (Appeals) is erroneous both on facts and In law. 2). The learned Commissioner of Income-Tax (Appeals) erred in confirming the addition made by the Assessing Officer of Rs.7

ACIT., EXEMPTIONS CIRCLE-1(1), HYDERABAD vs. PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA, HYDERABAD

In the result, the appeal of Revenue is allowed

ITA 1199/HYD/2024[2016-17]Status: DisposedITAT Hyderabad11 Feb 2025AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025

For Appellant: Shri RV. Chalam, C.AFor Respondent: Shri B. Balakrishna, CIT-DR
Section 11Section 11(1)(a)Section 12(1)Section 12ASection 143(2)Section 143(3)Section 144

condone the delay. In view of this difficulty, we are unable to accede to the prayer made on behalf of the assessee. We have also gone through the judgment of the Division Bench of this Court relied upon by the assessee. That was a case where the assessee was denied the benefit of Section

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

ITA 228/HYD/2021[2016-17]Status: DisposedITAT Hyderabad03 Feb 2022AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri H. SrinivasuluFor Respondent: Shri YVST Sai
Section 143(3)Section 92C

deemed international transaction and the Hon'ble DRP erred in holding this transaction as an international transaction. B. Provision of Information Technology enabled Services ('ITeS') 7. On the facts and in the circumstances of the case and in contrary to law, the Ld. TPO has erred and the Hon'ble DRP further erred in upholding/confirming the action

ADP PRIVATE LIMITED (31/10/2015),RANGA REDDY vs. DCIT, CIRCLE-1( 1), HYDERABAD

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

ITA 227/HYD/2021[2016-17]Status: DisposedITAT Hyderabad03 Feb 2022AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri H. SrinivasuluFor Respondent: Shri YVST Sai
Section 143(3)Section 92C

deemed international transaction and the Hon'ble DRP erred in holding this transaction as an international transaction. B. Provision of Information Technology enabled Services ('ITeS') 7. On the facts and in the circumstances of the case and in contrary to law, the Ld. TPO has erred and the Hon'ble DRP further erred in upholding/confirming the action