ASSIATANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-3(4), HYDERABAD vs. ZAINAB INVESTMENTS PRIVATE LIMITED , HYDERABAD

In the result, appeals filed by the Revenue and the assessee for the A

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.66/Hyd/2021 To 69/Hyd/2021 (निर्धारण वर्ा/A.Y: 2011-12, 2013-14, 2015-16 & 2016-17) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.70/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.111/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) M/S Zainab Investments Vs. Asst.Commissioner Of Income Tax Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 20/02/2025 Pronouncement:

House International (P) Ltd. (supra). Further, the Hon'ble Supreme Court in the case of Commissioner of Income-Tax, Orissa vs Orissa Corporation (P) Ltd. (supra) has considered similar issue and held that once, genuineness and creditworthiness and identity of investors are established, no additions can be made as cash credit, on the ground that investor company and directors have

ZAINAB INVESTMENTS PRIVATE LIMITED ,SECUNDERABAD,SECUNDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -3(4),HYDERABAD, HYDERABAD

In the result, appeals filed by the Revenue and the assessee for the A

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.66/Hyd/2021 To 69/Hyd/2021 (निर्धारण वर्ा/A.Y: 2011-12, 2013-14, 2015-16 & 2016-17) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.70/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.111/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) M/S Zainab Investments Vs. Asst.Commissioner Of Income Tax Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 20/02/2025 Pronouncement:

House International (P) Ltd. (supra). Further, the Hon'ble Supreme Court in the case of Commissioner of Income-Tax, Orissa vs Orissa Corporation (P) Ltd. (supra) has considered similar issue and held that once, genuineness and creditworthiness and identity of investors are established, no additions can be made as cash credit, on the ground that investor company and directors have

ASSIATANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE 3(4), HYDERABAD vs. ZAINAB INVESTMENTS PRIVATE LIMITED , HYDERABAD

In the result, appeals filed by the Revenue and the assessee for the A

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.66/Hyd/2021 To 69/Hyd/2021 (निर्धारण वर्ा/A.Y: 2011-12, 2013-14, 2015-16 & 2016-17) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.70/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.111/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) M/S Zainab Investments Vs. Asst.Commissioner Of Income Tax Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 20/02/2025 Pronouncement:

House International (P) Ltd. (supra). Further, the Hon'ble Supreme Court in the case of Commissioner of Income-Tax, Orissa vs Orissa Corporation (P) Ltd. (supra) has considered similar issue and held that once, genuineness and creditworthiness and identity of investors are established, no additions can be made as cash credit, on the ground that investor company and directors have

RAJENDER REDDY GUNNA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6, HYDERABAD

In the result, appeal ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

house property. Further, the assessee also could not be able to justify the amount received from his wife and mother. In absence of any evidence, the arguments of the assessee that, source for purchase of property, is out of amount received from HUF, mother and wife cannot be accepted. The Assessing Officer after considering the relevant facts, has rightly made

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE 3(4), HYDERABAD vs. ZAINAB INVESTMENTS PRIVATE LIMITED , HYDERABAD

House International (P) Ltd.(supra).\n38.\nIn view of this matter and considering the facts and\ncircumstances and also by following the ratios of case laws\ndiscussed herein above, we are of the considered view that the\nAssessing Officer is erred in making addition towards advances /\ninvestment received from the above companies as unexplained cash\ncredit

RAJENDER REDDY GUNNA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6, HYDERABAD

unexplained investment in house property for\nRs.9,08,650/-\n41. During the course of search proceeding, it is\nnoticed that, Mr. Krishna Chandra, son of the assessee had\nmade an investment for purchase of residential Flat-404, 5th\nFloor, Subhalaxmi Apartments, Green Hills Colony,\nKothapet, Hyderabad in January 2005. The assessee was\nasked to clarify the source for such investment

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. TARA CHAND BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3),, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. KAVYA BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

TARA CHAND BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. JHANSI RANI BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. SARAT GOPAL BOPPANA, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

KAVYA BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

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

credit risk and market risk. Therefore, opined that property received in pursuant to the joint development agreement become inventory of the assessee and thus, as per the provisions of Section 28(via) of the Act, which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property

RAJENDER REDDY GUNNA ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-6, HYDERABAD

credit of\nRs.1,30,94,500/- towards additions made on account of\nundisclosed income from land transactions on the basis of\n'Lokpriya' notebook found during the course of survey.\n23.\nThe next issue that came-up for consideration is\naddition towards donation of Rs.5,00,000/- from\nundisclosed income.\n24.\nDuring the course of search at the residential\npremises

RAJENDER REDDY GUNNA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6, HYDERABAD

In the result, appeal ITA

unexplained investment in purchase of flat held\nby son Sri Krishna Chandra though there is no evidence that the\nassessee has invested the same.\n7. For these and other grounds that may be urged, it is prayed that\nthe Hon'ble Tribunal may be pleased to allow the appeal.”\n38.\nThe first issue that came-up for consideration\nfrom ground

RAJENDER REDDY GUNNA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6, HYDERABAD

unexplained investment in purchase of flat held\nby son Sri Krishna Chandra though there is no evidence that the\nassessee has invested the same.\n6. The learned CIT(A) though states that the AO has discussed the\nreasons elaborately in the assessment order failed to deal with\nthe submissions of the assessee both at the time of assessment\nand

KANISHKA GUPTA,,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(1), HYDERABAD

In the result, all the appeals of assessees are dismissed

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

unexplained credit taxed in the hands of the firm, in their respective hands. The appellants and the firm are different entitites and therefore needs to be taxed separately in their own hands especially when the nature is different and it is important to note that when the incriminating documents of Rs.70,00,000/ - pertaining to both the appellants were found

SUPREME AGRO,HYDERABAD vs. ACIT CENTRAL CIRCLE-3 (1), HYDERABAD

In the result, all the appeals of assessees are dismissed

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

unexplained credit taxed in the hands of the firm, in their respective hands. The appellants and the firm are different entitites and therefore needs to be taxed separately in their own hands especially when the nature is different and it is important to note that when the incriminating documents of Rs.70,00,000/ - pertaining to both the appellants were found