RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, three appeals i

rectification order passed by the ACIT/CPC u/s 154\ndated 27/09/2022 becomes infructuous. In our considered view, the\nobservation of the learned CIT (A) in para 6.2.8 of his order is beyond the\nscope of powers of the CIT (A) because, the CIT (A) does not have any\npower to give any direction or finding in respect of issues which

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

rectification order passed by the ACIT/CPC u/s 154\ndated 27/09/2022 becomes infructuous. In our considered view, the\nobservation of the learned CIT (A) in para 6.2.8 of his order is beyond the\nscope of powers of the CIT (A) because, the CIT (A) does not have any\npower to give any direction or finding in respect of issues which

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

rectification order passed by the ACIT/CPC u/s 154\ndated 27/09/2022 becomes infructuous. In our considered view, the\nobservation of the learned CIT (A) in para 6.2.8 of his order is beyond the\nscope of powers of the learned CIT (A) because, the CIT (A) does not have any\npower to give any direction or finding in respect of issues

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

rectification order passed by the ACIT/CPC u/s 154\ndated 27/09/2022 becomes infructuous. In our considered view, the\nobservation of the learned CIT (A) in para 6.2.8 of his order is beyond the\nscope of powers of the CIT (A) because, the CIT (A) does not have any\npower to give any direction or finding in respect of issues which

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

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

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

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

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

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

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

APACHE FOOTWEAR INDIA PRIVATE LIMITED,MAMBATTU VILLAGE vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CIRCLE-1(1), TIRUPATI

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

rectification order u/s. 92CA(3) r.w.s. 154 dated 18.02.2021 reducing the enhancement from Rs.15,45,28,798 to Rs.11,72,618/-. 3.4 Accordingly, the income returned was enhanced as per the provisions of section 92CA(3) of the Act by a sum of Rs.11,72,618/- towards arm’s length price determined by the TPO u/s. 92CA

MICROSOFT GLOBAL SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes

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

rectification was sought by the assessee. The final adjustments as per the DRP's directions, totaled to Rs. 91,33,00,000/- for Software Development Services was added to the total income of the assessee and thereafter, passed the assessment order on 22.04.2021 u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act. Thereafter penalty proceedings under Section

MADIYAM VENKATARAVINDRA REDDY, ANANTAPUR,HYDERABAD vs. ITO, WARD-3, ANANTAPUR, ANANTAPUR

In the result, appeal of the assessee is allowed in part

Bench: Shri J. Sudhakar Reddy

154 of the Act on 26.08.2010 proposing rectification of certain mistakes pertaining to expenditure claimed on vehicle maintenance and TDS. No action was taken on this notice. Later a notice u/s 148 of the Act was issued to the assessee based on a finding in the audit report by the Income Tax Officer (IAP), Tirupati. An assessment order u/s

SUDHEER PARIMALA,HYDERABAD vs. INCOME TAX OFFICER, WARD-10(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.758/Hyd./2025 Assessment Year 2015-2016 Sudheer Parimala, The Income Tax Officer, Hyderabad – 500 016. Vs. Ward-10(1), Hyderabad. Pan Ahppp7572E Pin - 500 004. Telangana (Appellant) (Respondent) For Assessee : Ca Kranthi Palivela & Ca Mrudulatha For Revenue : Dr. Sachin Kumar, Sr. Ar Date Of Hearing : 24.03.2026 Date Of Pronouncement : 17.04.2026 आदेश/Order

penalty proceedings initiated under sections 271(1)(c) and 271F;  And grant such other relief(s) as may be deemed fit in the interest of justice.” 3. The assessee also raised the following additional grounds of appeal: 1. “On the facts and circumstances of the case and in law, the Income Tax Officer, Ward 10(1), Hyderabad ('Ld. AO") erred

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

rectification application under section 154 of the Act or appeal under section 246 of the Act. The assessee is required to choose the right course of action diligently which depends upon different facts and circumstances. 25.5 Nevertheless, the object for making the adjustment in the intimation under section 143(1) of the Act or framing the assessment under section

M. CHANDRA SEKHAR GOUD,,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

Bench: Shri S.S.Godara

154 action only there is hardly any dispute in light of hon'ble apex court’s decision in T.S.Balaram, ITO Vs. M/s.Volkart Brothers [82 ITR 50] (SC) provides that such a rectification is meant for apparent mistake(s) than those requiring detailed roving enquiries. It is made clear that the Assessing Officer had indeed issued Section 148 notice resulting

M. CHANDRA SEKHAR GOUD,,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

Bench: Shri S.S.Godara

154 action only there is hardly any dispute in light of hon'ble apex court’s decision in T.S.Balaram, ITO Vs. M/s.Volkart Brothers [82 ITR 50] (SC) provides that such a rectification is meant for apparent mistake(s) than those requiring detailed roving enquiries. It is made clear that the Assessing Officer had indeed issued Section 148 notice resulting