MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

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

b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the assessment year relevant to the previous year in which search is conducted. Applying this yardstick, the six years would go up to 2013-14. The search assessment year, namely, 2019-20 has to be excluded. This is because, the statute talks

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

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

b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the assessment year relevant to the previous year in which search is conducted. Applying this yardstick, the six years would go up to 2013-14. The search assessment year, namely, 2019-20 has to be excluded. This is because, the statute talks

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

In the result appeals filed by the Revenue\nITA

1) or 139(5) of the Act.\niii.\nWhether on the facts and circumstances of the case,\nand in law, the Id. CIT(A) erred in not holding that the\nProvisions of sections 153A to 153C cannot be\ninterpreted to be further innings for AO and/or assessee\nbeyond provisions of sections 139, 147 and 263, as\nsuch no fresh claim

MSN ORGANICS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

b) states that the assessing officer shall assess or reassess the total\nincome of six years immediately preceding the assessment year relevant to the\nprevious year in which search is conducted. Applying this yardstick, the\nsix years would go up to 2013-14. The search assessment year, namely,\n2019-20 has to be excluded. This is because, the statute talks

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

1) or 139(5) of the Act.\niii.\nWhether on the facts and circumstances of the case,\nand in law, the Id. CIT(A) erred in not holding that the\nProvisions of sections 153A to 153C cannot be\ninterpreted to be further innings for AO and/or assessee\nbeyond provisions of sections 139, 147 and 263, as\nsuch no fresh claim

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

b) states that the assessing officer shall assess or reassess the total\nincome of six years immediately preceding the assessment year relevant to the\nprevious year in which search is conducted. Applying this yardstick, the\nsix years would go up to 2013-14. The search assessment year, namely,\n2019-20 has to be excluded. This is because, the statute talks

DY.COMMISSIONER OF INCOME TAX, CIRCLE 2(2), HYDERBAD vs. SEW INFRASTUCTURE LIMITED, HYDERABAD

1) or 139(5) of the Act.\n\niii.\nWhether on the facts and circumstances of the case,\nand in law, the Id. CIT(A) erred in not holding that the\nProvisions of sections 153A to 153C cannot be\ninterpreted to be further innings for AO and/or assessee\nbeyond provisions of sections 139, 147 and 263, as\nsuch no fresh

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

b) states that the assessing officer shall assess or reassess the total\nincome of six years immediately preceding the assessment year relevant to\nthe previous year in which search is conducted. Applying this yardstick, the\nsix years would go up to 2013-14. The search assessment year, namely,\n2019-20 has to be excluded. This is because, the statute talks

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

b) states that the assessing officer shall assess or reassess the total\nincome of six years immediately preceding the assessment year relevant to\nthe previous year in which search is conducted. Applying this yardstick, the\nsix years would go up to 2013-14. The search assessment year, namely,\n2019-20 has to be excluded. This is because, the statute talks

MSN ORGANICS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

b) and (c) specified in\n32\nITA Nos.1060 to 1063/Hyd/2024\nthe said forth proviso are cumulatively fulfilled, the Assessing Officer\ndoes not get jurisdiction to issue notice u/s 153A of the Act for the\n“relevant assessment year or years”.\n30.\nThe learned counsel for the assessee further referring to the\nfacts of the present case submitted that

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

b) states that the assessing officer shall assess or reassess the total\nincome of six years immediately preceding the assessment year relevant to the\nprevious year in which search is conducted. Applying this yardstick, the\nsix years would go up to 2013-14. The search assessment year, namely,\n2019-20 has to be excluded. This is because, the statute talks

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

b) of Section 153A(1)\nwherein it is provided that the AO shall assess or\nreassess the total income for each of the six assessment\nyears as mentioned above. The second proviso\ncontemplates that if any assessment relating to any\n assessment year falling within the period of six\n assessment years is pending on the date of initiation

MSN ORGANICS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

b) and (c) specified in\n32\nITA Nos.1060 to 1063/Hyd/2024\nthe said forth proviso are cumulatively fulfilled, the Assessing Officer\ndoes not get jurisdiction to issue notice u/s 153A of the Act for the\n“relevant assessment year or years”.\n30. The learned counsel for the assessee further referring to the\nfacts of the present case submitted that

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

disallowed the assessee’s claim for deduction under section 80C of the Act of Rs. 66,982/-. 6. Accordingly, the AO vide his order under section 147 of the Act, dated 26/03/2025, determined the income of the assessee at Rs. 8,35,157/-. 7. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

disallowed the assessee’s claim for deduction under section 80C of the Act of Rs. 66,982/-. 6. Accordingly, the AO vide his order under section 147 of the Act, dated 26/03/2025, determined the income of the assessee at Rs. 8,35,157/-. 7. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success

RASHID HUSSAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(3), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

disallowance of his claim for deduction of expenditure of Rs.16,33,050/-. Accordingly, the CIT(A) partly allowed the appeal. 5 Rashid Hussain vs. ACIT 8. The assessee being aggrieved with the order of the CIT(A) has carried the matter in appeal before us. 9. We have heard the Ld. Authorised Representatives of both parties, perused the orders

DCIT., CIRCLE-8(1), HYDERABAD vs. DBS TECHNOLOGY SERVICES INDIA PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Deputy Commissioner Of Vs. M/S. Dbs Technology Income Tax, Services India Private Circle – 8(1), Limited, Hyderabad. Hyderabad. Pan : Aafcd5584N (Appellant) (Respondent) C.O.No.2/Hyd/2023 Assessment Year 2019-20 Dbs Technology Services India Vs. Deputy Commissioner Of Private Limited, Income Tax, Circle – 8(1), Hyderabad. Hyderabad. Pan : Aafcd5584N (Cross Objector / (Appellant/Revenue) Respondent) Assessee By: Sri M. P. Lohia, C.A. Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 11.07.2023 Date Of Pronouncement: 21.07.2023 आदेश / O R D E R Per Laliet Kumar, Jm: The Appeal & Cross-Objection Filed By The Revenue For A.Y. 2019-20 Arise From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi

disallowance, and also in a case where NO response is received, then within thirty days of the issue of such intimation, department is free to make such adjustment. 8. On going through the above intimation made under section 143(1), CPC has not followed the above provisos by giving proper opportunity to the assessee to defend its case

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

153A of the Act, filed return of income declaring income at Rs.26,50,14,278/- after claiming deduction u/s. 80IA of the Act for Rs.2,50,55,348/- The Assessing Officer disallowed the claim of the assessee u/s. 80IA stating that the deduction was not claimed in the original return of income and the assessee is not the owner