NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the assessment

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the assessment

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

3) r.w.s. 263 r.w.s.\n144B of the Income-tax Act, 1961, on 24.09.2021 and determined\nthe total income at Rs. 28,46,91,790/- by making additions of Rs.\n8,77,278/- towards disallowance of interest on TDS and further\ndisallowance of EPF & ESI under Section 36(1)(va) for Rs.\n3,66,095/-, addition towards disallowance of interest expenditure

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU , HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance in respect of the items of club fees, gifts and presents, etc., then in view of our discussion as above, he would have been justified as per Explanation 3 to reduce the claim of deduction under sections 80HH and 80-I as well.” 18. With regard to the Revenue's reliance on the judgment in the case of Govindaraju

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

disallowance in respect of the items of club fees, gifts and presents, etc., then in view of our discussion as above, he would have been justified as per Explanation 3 to reduce the claim of deduction under sections 80HH and 80-I as well.” 18. With regard to the Revenue's reliance on the judgment in the case of Govindaraju

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

131 of the Act, have confirmed execution of work and furnished supporting details, though some had initially made contrary statements during search. 75. We further find that, the primary objections of the Revenue such as engagement of employees of group companies as sub- contractors, alleged lack of proper documentation and appraisal systems, deficiencies pointed out in internal audit reports

AMARA RAJA POWER SYSTEMS LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

disallowances arising out of the payments made\nto the contractors, therefore, the Pr. CIT had wrongly observed that\nthe A.O. had passed the assessment order without making\ninquiries or verification that should have been made. The Ld. A.R.\nfurther submitted that the Pr. CIT had, based on his incorrect\nobservations, triggered the “Explanation 2(a)” to Section