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

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

145 of the Act. 12. The assessee has relied upon case-law of the Hyderabad Tribunal in the case of BHAGYANAGAR CONSTRUCTION (P) 124) VS INCOME TAX OFFICER vide 1993 (046) ITD-0236-THYD dated 12.04.1993 where in it was held that “in case of a building contractor, the revenue need not wait till the completion of the tract

INDRANI PRASAD ,NEW DELHI vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, HYDERABAD

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

271 (l)(G), 271A and 2718. Section 158 BFA provides [or levy of interest and penalty in cases of search on .or after January 1, 1997. Section 158 BO specifies the authorities competent to make the block assessment. Section 158 BH provides for application of all the other provisions of this Act, except those as provided in Chapter

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. INDRANI PRASAD , NEW DELHI

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

271 (l)(G), 271A and 2718. Section 158 BFA provides [or levy of interest and penalty in cases of search on .or after January 1, 1997. Section 158 BO specifies the authorities competent to make the block assessment. Section 158 BH provides for application of all the other provisions of this Act, except those as provided in Chapter

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

D S R INFRASTRUCTUREPRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE- 1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DCIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

D S R INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

145 of the Act. 1.3. Ought to have appreciated the fact that the outstanding receivables are accrued from the sale of services rendered to the AE during the normal course of business and hence it cannot be equated to the term 'capital financing' as interpreted in section 92B of the Act. 1.4. Ought to have appreciated the fact that

MBS IMPES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

145(3) of the Act. . "as Pvt. Ltd. 20. Without prejudice to other grounds, The Ld.CIT (A) erred in upholding decision of the AO in estimating profit of the appellant at 3.5% of the amount of Rs. :- 7 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 34,60,47,806/- which has been treated

MBS JEWELLER PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3, HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

145(3) of the Act. . "as Pvt. Ltd. 20. Without prejudice to other grounds, The Ld.CIT (A) erred in upholding decision of the AO in estimating profit of the appellant at 3.5% of the amount of Rs. :- 7 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 34,60,47,806/- which has been treated

GSS INFOTECH LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

3) of the Act for Rs.1,49,75,581/- towards Interest on Receivables on the basis of hypothetical and notional basis without being any material on record to show that the interest should be charged in the present case. 3.1 Erred in re-characterizing the nature of transaction from 'Receivable' to 'loan' which is not permissible u/s. 145

GSS INFOTECH LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

3) of the Act for Rs.1,49,75,581/- towards Interest on Receivables on the basis of hypothetical and notional basis without being any material on record to show that the interest should be charged in the present case. 3.1 Erred in re-characterizing the nature of transaction from 'Receivable' to 'loan' which is not permissible u/s. 145

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

penalty under section\n271(1)(c) of the Act on 11/07/2025 was dropped in its new email account,\ni.e., \"accounts@virchowpetro.com”, therefore, in our view the same\nexplain the reason leading to the delay in filing the preset appeal, which,\nthus, merits to be condoned. Our aforesaid view that a liberal approach\nshould be taken while considering an application seeking condonation

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

3. 3.2.7. In view of the above, the Appellant wishes to submit that the contention of the learned AO to treat the CWIP amount as unexplained investment is not justified and devoid of merits. Notwithstanding and without prejudice to the above, 3.2.8. The Appellant wishes to place reliance on the following judicial decisions which have held that an expenditure