MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

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

revision u/s 263. I therefore, set-aside the orders passed u/s 143(3) r.w.s 153A on 31.12.2007 for the Asst. Years 2000-01 to 2006- 07 and direct the Assessing Officer to pass assessment orders afresh as per Madhucon Projects Limited, Hyderabad. law after making proper enquiry. He is directed to allow an opportunity of being heard to the aesessee

AGRO TECH FOODS LIMITED., SEC'BAD,SECUNDERABAD vs. DCIT, CIRCLE-1(1), HYD, HYDERABAD

In the result, appeal in ITA No

Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singh

disallowed the balance being Rs.6,93,37,003/- and accordingly brought it to tax. 2.2. Subsequently, the CIT (IT & TP) assuming powers u/s 263 of the I.T. Act, perused the TPO’s order and observed that the order passed by the TPO is erroneous in so far as it is prejudicial to the interest of the revenue. He observed that

INDUKURI SUNDARI, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeals of both assessee’s are allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blesmt Indukuri Sundari V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aakpi8049P (Appellant) (Respondent) Shri Indukuri Syam Prasad Reddy V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aadpi1621C (Appellant) (Respondent) : Shri Mohammad Afzal Assessee By Department By : Shri M.V.S.T. Sai

disallowance made by the Assessing Officer is to be struck down. 13. Learned Counsel for the assessee submitted that the order u/s.263 was passed on 30.03.2012, further, consequent to reopening of the assessment u/s 263, the Assessing Officer, Central Circle-3 issued notice u/s 143(2) on 30.03.2012, and same is served on the assessee on 31.03.2012, therefore

INDUKURI SYAM PRASAD REDDY, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeals of both assessee’s are allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blesmt Indukuri Sundari V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aakpi8049P (Appellant) (Respondent) Shri Indukuri Syam Prasad Reddy V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aadpi1621C (Appellant) (Respondent) : Shri Mohammad Afzal Assessee By Department By : Shri M.V.S.T. Sai

disallowance made by the Assessing Officer is to be struck down. 13. Learned Counsel for the assessee submitted that the order u/s.263 was passed on 30.03.2012, further, consequent to reopening of the assessment u/s 263, the Assessing Officer, Central Circle-3 issued notice u/s 143(2) on 30.03.2012, and same is served on the assessee on 31.03.2012, therefore

JVR RETAILS PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE -2(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2012-13 Jvr Retails Private Limited Vs Dcit, Circle-2(1) C/O. Murali & Co. . Hyderabad Chartered Accountants 6-3-655/2/3, Somajiguda Hyderabad-500 082 Pan : Aaccv9428J (Appellant) (Respondent) Assessee By: Shri M.V.Joshi Appeared For P.Murali Mohan Rao, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.01.2023 Date Of Pronouncement: 31.01.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.03.2021 Passed U/S. 263 By The Learned Principal Commissioner Of Income Tax -2, Hyderabad Relating To A Y 2012-13. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Domestic Company Engaged In The Business Of Retails & Manufacturing Of Jewelry. It Filed Its Return Of Income Declaring Total Income Of Rs. 49,97,390/- On 08.09.2012 Which Was Processed U/S 143(1) On 21.02.2013. Subsequently, The Ao Reopened The Assessment By Recording Reasons As Per Provisions Of Section 147. The Reasons To Believe Which Was Put Up Before The Ld.Pcit-2 For Approval & Which Has Been Reproduced By The Ao In The Body Of The Assessment Order Read As Under:-

revise the order u/s. 263 by taking another view. Further, the assessment was reopened only for the purpose of verification of Rs.1,65,00,000/- and the amount of Rs. 4,82,25,000/- was not a subject matter of reassessment before the AO. Therefore, on this issue also, the ld.PCIT cannot invoke jurisdiction u/s. 263 of the I.T.Act

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring to the decision

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring to the decision

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD, HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. CHINTHAKUNTA RAMESH SRIDEVI, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

GVPR ENGINEERS LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1(3) , HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CC-1(3), HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE1(3), HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD, HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

disallowance u/s 80IA(4)(iv)(b) of Rs.14,59,30,268/- and Rs.59,03,406/-. Page 2 of 34 ITA Nos 697 to 701 and 750 to 754 of 2020 4.1 A search and seizure operation u/s 132 of the I.T. Act was conducted on 2.11.2017 along with group cases of M/s. GVPR Engineers Ltd. In response to notice u/s

K.RAHEJA IT PARK (HYDERABAD) PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Laxmi Prasad Sahushri Assessment Year: 2011-12 K. Raheja It Park ` Dy. Commissioner Of (Hyderabad) Pvt. Ltd., Income-Tax, Hyderabad. Circle – 2(1), Hyderabad. Pan – Aacck 1914G (Appellant) (Respondent) Assessee By: Shri Vijay Mehta & Ms. Aarthi Sathe Revenue By Shri Yvst Sai Date Of Hearing: 18/03/2021 Date Of Pronouncement: 06/05/2021

u/s 263 and the Assessing Officer is directed to revise the Assessment Order by disallowing the deduction claim u/s 80IA

THE CITIZEN CO-OP-SOCIETY LIMITED,HYDERABAD vs. DCIT., CIRCLE-9(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.388/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) The Citizen Cooperative Vs. Dy.Cit Society Limited, Hyderabad Circle 9 (1) Pan:Aaaat3952F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ravi Bharadwaj, Ca राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 07/07/2025 घोषणा की तारीख/Pronouncement: 30/07/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Revision Order Dated 13/02/2025 Of The Learned Pr. Cit Passed U/S 263 Of The Act For The A.Y.2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Order Passed By The Learned Principal Commissioner Of Income Tax (Pcit) - Iv U/S 263 Of The Act Is Erroneous Both In Law & Facts Of The Case. 2. The Order Passed By The Learned Principal Commissioner Of Income Tax (Pcit) U/S 263 Of The Act Is Bad In Law & Need To Be Quashed.

revision order dated 13/02/2025 of the learned Pr. CIT passed u/s 263 of the Act for the A.Y.2020-21. 2. The assessee has raised the following grounds of appeal: “1. The order passed by the Learned Principal Commissioner of Income Tax (PCIT) - IV u/s 263 of the Act is erroneous both in law and facts of the case. 2. The Order