SRIDHAR REDDY BAYAPU,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

Bench: Us:

House No. 10-3-734/3 (admeasuring 271.66 square yards) situated at Vijaya Nagar Colony, Mallepally, Hyderabad, Telangana for a sale consideration of Rs. 72.54 lacs. That prior to the sale of the aforesaid property the assessee and his wife Smt. Indira Reddy, had vide an “agreement to sell”, dated 22/06/2015 agreed to purchase a semi-finished Villa

NARSI REDDY KOMATIREDDY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

47)(v) of the Act, reference has been made to Section 53A of the Transfer of Property Act, 1882, which incorporates the doctrine of equity of part performance of contract. Section 53A introduces in limited form the doctrine of equity of part performance in India where requirements mentioned in the provisions are satisfied (see Ramachandrayya vs. Satyanarayana11). Section

NARSI REDDY KOMATIREDDY,HYDERABAD vs. SRIG. SANTOSH KUMAR, DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

47)(v) of the Act, reference has been made to Section 53A of the Transfer of Property Act, 1882, which incorporates the doctrine of equity of part performance of contract. Section 53A introduces in limited form the doctrine of equity of part performance in India where requirements mentioned in the provisions are satisfied (see Ramachandrayya vs. Satyanarayana11). Section

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

section 147 / 148 of the Act, the coordinate Bench had held as under : “22. Coming back to our point we have to examine whether protective assessment/addition is possible under section 147 in respect of the same person and for the same period. When a regular assessment is made and later on it comes to the notice of the Assessing Officer

NAVEEN KUMAR MUSINIPALLY,USA vs. ADIT (INT-TAXN)-1, HYDERABAD

In the result, appeal of the Assessee partly allowed

house received by the assessee in pursuance to JDA of the property as deduction u/sec.54F of the Act.\n9. Aggrieved by the order of the learned CIT(A), the assessee is now, in appeal before the Tribunal.\n10. CA, KC Devdas, Learned Counsel for the Assessee referring to the notice issued by the ACIT, [INTL-TAXN

RACHIT V SHAH,HYDERABAD vs. ITO, WARD-7(3), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 54F of the Act, if he had more than one residential house in his name before investing. In the present case, the assessee has shown the house property income from two houses, namely, oneself occupied (at Door No.3-6-305/43,43/1, Avanthi Nagar, Basheerbagh, Hyderabad) and one let out (at Sy.No.52 & 53, Saheb Nagar, Khurd Village, LB Nagar, Hyderabad). However

SAHODHAR REDDY MUDDASANI,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1619/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Sahodhar Reddy Vs. Dy.Cit Muddasani Central Circle 1(3) Hyderabad Hyderabad Pan:Aelpm9122N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Shri C Maheshwar Reddy राज" व "ारा/Revenue By: Shri Sankar Pandi P, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Sahodhar Reddy Muddasani (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) Dated 24.09.2025 For The A.Y. 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

house property. The assessee filed his return of income for the Assessment Year 2016–17 on 16.01.2018 declaring total income of Rs.5,85,350/-. A search and seizure operation under section 132 of the Income Tax Act, 1961 (“the Act”) was conducted on 09.08.2018 in the case of the assessee along with M/s Moksha Infracon Private Limited ( “the developer

MANOHAR REDDY CHERUKU,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(3), HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1625/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Manohar Reddy Vs. Dy.Cit Cheruku, Hyderabad Central Circle 1(3) Pan:Aelpc8785R Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri C Maheshwar Reddy, Ca राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 02/12/2025 घोषणा की तारीख/Pronouncement: 05/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

house property. The assessee filed his return of income for the Page 2 of 8 ITA No 1625 of 2025 Manohar Reddy Cheruku assessment year 2016–17 on 31.03.2017 admitting a total income of Rs.5,98,860/-. A search and seizure operation under section 132 of the Income Tax Act, 1961 (“the Act”) was conducted on 09.08.2018 in the case

DCIT., (INTERNATIONAL TAXATION)-1, HYDERABAD vs. SYAMA REDDY MALI REDDY, HYDERABAD

47), which defines the term transfer in relation to a capital asset. In the\nlight of the factual matrix, it was observed that the intention\nbehind Section 54 was to give relief to a person who had transferred his\nresidential house and had purchased another residential house within\ntwo years of transfer or had purchased a residential house one year

SURENDER KUMAR BHOJWANI,HYDERABAD vs. ITO, INTL. TAXTION -1, HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

property. According to the development agreement, the assesse was entitled to 48% of the super built-up area in the form of four residential flats. The Hon’ble High Court had held that the four residential flats constitute “a residential house” for the purpose of Section 54 of the Act. Also, we may herein observe that the Hon’ble High

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. KAVYA KAZA, HYDERABAD

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

Section 2(47)(v) of the Act. 3. As the facts and issues in both the appeals are same, except the amounts involved, we are reproducing the facts of appeal in ITA No.440/Hyd/2022 for the sake of brevity. 4. Facts of the case, in brief, are that assessee is an individual filed the original return of income

ACIT, CENTRAL CIRCLE-2(2) , HYDERABAD vs. LAKSHMI NARAYANA KAZA, , PEDAGONNURU

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

Section 2(47)(v) of the Act. 3. As the facts and issues in both the appeals are same, except the amounts involved, we are reproducing the facts of appeal in ITA No.440/Hyd/2022 for the sake of brevity. 4. Facts of the case, in brief, are that assessee is an individual filed the original return of income

DIWAKAR REDDY CHINTAKUNTALA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(3), HYDERABAD

In the result, appeal in ITA No

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

47), which defines the term transfer in relation to a capital asset. In the light of the factual matrix, it was observed that the intention behind Section 54 was to give relief to a person who had transferred his residential house and had purchased another residential house within two years of transfer or had purchased a residential house one year

INDUMATI CHINTAKUNTALA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(3), HYDERABAD

In the result, appeal in ITA No

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

47), which defines the term transfer in relation to a capital asset. In the light of the factual matrix, it was observed that the intention behind Section 54 was to give relief to a person who had transferred his residential house and had purchased another residential house within two years of transfer or had purchased a residential house one year

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE- 1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

47. (4) For the purposes of this section, "new asset" means any new plant or machinery (other than a ship or aircraft) but does not include-- (a) any plant or machinery, which before its installation by the assessee, was used either within or outside India by any other person; (b) any plant or machinery installed in any office premises

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE-1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

47. (4) For the purposes of this section, "new asset" means any new plant or machinery (other than a ship or aircraft) but does not include-- (a) any plant or machinery, which before its installation by the assessee, was used either within or outside India by any other person; (b) any plant or machinery installed in any office premises

DCIT., CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LIMITED, KOTHAGUDEM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

47. (4) For the purposes of this section, "new asset" means any new plant or machinery (other than a ship or aircraft) but does not include-- (a) any plant or machinery, which before its installation by the assessee, was used either within or outside India by any other person; (b) any plant or machinery installed in any office premises

DCIT., CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LTD, KOTHAGUDEM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

47. (4) For the purposes of this section, "new asset" means any new plant or machinery (other than a ship or aircraft) but does not include-- (a) any plant or machinery, which before its installation by the assessee, was used either within or outside India by any other person; (b) any plant or machinery installed in any office premises