THALLA SRISAILAM GOUD,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 9(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

Income-tax (Appeals)/NFAC erred rejecting the legal grounds raised by the Appellant w.r.t. initiation of reassessment proceeding without following due procedure prescribed under the statute. 4. The NFAC ought to have appreciated that the Assessing Officer had not recorded proper satisfaction and further initiated reassessment proceedings under the old law beyond the period of six years. from

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

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

business of development of infrastructure projects, filed its original return of income for the assessment year 2009-10 on 21-09-2009, admitting a total income of Rs.113,58,17,240/-. The assessment has been completed under Section 143(3) of the Income Tax Act, 1961 on 27.12.2011 accepting the returned income. A search and seizure operation under section

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

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

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

ACIT CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

PITTI HOLDINGS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

income for the assessment year 2018-19 on 27-09-2018 and returned current year loss at Rs.1.55,676/-. The case was selected for complete scrutiny under CASS and assessment uls 143(3) was passed on 22-01-2021 by the AD, National e- Assessment Centre, Delhi. The issue for CASS selection was i) Business Loss ii) Share Capital/Other Capital

GARIKAPATI RAGHURAM, HYDERABAD,HYDERABAD vs. DCIT, INTERNATIONAL TAXATION, HYDERABAD, HYDERABAD

Appeal is dismissed and additional ground No

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

business income' is Rs.7,37,449/-. However, 30% standard deduction is allowable under the head 'income from House Property’ ie., Rs.2,05,516/-. The difference between these two figures (Rs.7,37,449 - Rs.2,05,516) ie., Rs.5,31,933/- is taken for levy of penalty u/s.271(1)(c) of the I.T. Act. The income tax on this amount is Rs.1

CANARA SECURITIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2010-11 Canara Securities Ltd., Vs. Dy. Commissioner Of Hydereabad. Income-Tax, Central Circle – 2(1), Pan – Aaacc8283G Hyderabad. Appellant Respondent Assessee By: Shri Ramkishore Jhawar Revenue By: Shri Nilanjan Dey Date Of Hearing: 08/05/2019 Date Of Pronouncement: 03/07/2019 O R D E R

business loss of Rs. 36,52,900/- and unabsorbed depreciation allowance of Rs. 6,660/-. The return of income was processed u/s 143(1) of the Income-tax Act, 1961 (in short ‘the Act’) and there is no 143(3) assessment in this case. 2.1 Subsequently, the AO received specific information that the assessee had contrived losses by using Client

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. ASIAN INFRA ESTATES LIMITED, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singh, Hon'Ble Vice- & Shri Manjunatha, G. Accountant Hon'Bleआ.अपी.सं /Ita Nos.683/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2019-20) Asstt. Commissioner Of Vs. Asian Dwellings Llp Income Tax, Hyderabad Central Circle 2(3) Pan:Abmfa1423A Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.684 & 685/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2018-19 & 2019-20) Asstt. Commissioner Of Vs. Asian Infra Estates Ltd Income Tax, Hyderabad Pan:Aabca7660 & Central Circle 2(3) Hyderabad Asian Infra Estates Llp Hyderabad Pan:Abnf5143L (Appellant) (Respondent) राज" व "ारा/Revenue By:: Shri B. Balakrishna, Dr िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca सुनवाई की तारीख/Date Of Hearing: 26/09/2024 घोषणा की तारीख/Pronouncement: 25/10/2024 आदेश/Order Per Manjunatha, G. A.M These 3 Appeals Filed By The Revenue Are Directed Against The Separate, But Identical Orders Passed By The Learned

reassess total income for entire six years block Page 19 of 21 ITA Nos 683 684 and 685 Asian Dwellings LLP and Asian Infra Estates Ltd assessment period even in case of completed/unabated assessment – Held, yes – Whether I case of search u/s 132 or requisition u/s 132A, Assessing Officer assumes jurisdiction for block assessment u/s 2153A and that all pending

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. ASIAN DWELLINGS LLP, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singh, Hon'Ble Vice- & Shri Manjunatha, G. Accountant Hon'Bleआ.अपी.सं /Ita Nos.683/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2019-20) Asstt. Commissioner Of Vs. Asian Dwellings Llp Income Tax, Hyderabad Central Circle 2(3) Pan:Abmfa1423A Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.684 & 685/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2018-19 & 2019-20) Asstt. Commissioner Of Vs. Asian Infra Estates Ltd Income Tax, Hyderabad Pan:Aabca7660 & Central Circle 2(3) Hyderabad Asian Infra Estates Llp Hyderabad Pan:Abnf5143L (Appellant) (Respondent) राज" व "ारा/Revenue By:: Shri B. Balakrishna, Dr िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca सुनवाई की तारीख/Date Of Hearing: 26/09/2024 घोषणा की तारीख/Pronouncement: 25/10/2024 आदेश/Order Per Manjunatha, G. A.M These 3 Appeals Filed By The Revenue Are Directed Against The Separate, But Identical Orders Passed By The Learned

reassess total income for entire six years block Page 19 of 21 ITA Nos 683 684 and 685 Asian Dwellings LLP and Asian Infra Estates Ltd assessment period even in case of completed/unabated assessment – Held, yes – Whether I case of search u/s 132 or requisition u/s 132A, Assessing Officer assumes jurisdiction for block assessment u/s 2153A and that all pending

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. ASIAN INFRA ESTATES LLP, SECUNDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singh, Hon'Ble Vice- & Shri Manjunatha, G. Accountant Hon'Bleआ.अपी.सं /Ita Nos.683/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2019-20) Asstt. Commissioner Of Vs. Asian Dwellings Llp Income Tax, Hyderabad Central Circle 2(3) Pan:Abmfa1423A Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.684 & 685/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2018-19 & 2019-20) Asstt. Commissioner Of Vs. Asian Infra Estates Ltd Income Tax, Hyderabad Pan:Aabca7660 & Central Circle 2(3) Hyderabad Asian Infra Estates Llp Hyderabad Pan:Abnf5143L (Appellant) (Respondent) राज" व "ारा/Revenue By:: Shri B. Balakrishna, Dr िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca सुनवाई की तारीख/Date Of Hearing: 26/09/2024 घोषणा की तारीख/Pronouncement: 25/10/2024 आदेश/Order Per Manjunatha, G. A.M These 3 Appeals Filed By The Revenue Are Directed Against The Separate, But Identical Orders Passed By The Learned

reassess total income for entire six years block Page 19 of 21 ITA Nos 683 684 and 685 Asian Dwellings LLP and Asian Infra Estates Ltd assessment period even in case of completed/unabated assessment – Held, yes – Whether I case of search u/s 132 or requisition u/s 132A, Assessing Officer assumes jurisdiction for block assessment u/s 2153A and that all pending

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

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

business of Infrastructure Projects. In the original return of income filed on 28.11.2013 for the impugned assessment year 2013-2014, the assessee declared income at Rs.104,87,01,480/-, but has not claimed any deduction u/sec.80IA(4) of the Act. In this case, a search and seizure operation u/sec.132 of the Act was conducted and in response to notice u/sec.153A

SPR INFRASTRUCTURE INDIA LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-3(2), HYDERABAD, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu(Through Virtual Hearing)

reassessment proceedings it is not open to an assessee to seek a review of the concluded item, unconnected with escapement of income.” 13. In view of the legal position as enunciated by the Hon’ble Supreme Court, the contention of assessee to revise incomes and accounts can not be accepted as the proceedings are initiated for bringing

SHIVA RANJANI VEJJA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-12(2) , HYDERABAD

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

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

business income. Subsequently, based on the source of income for AY 2017- 18 which was shown as salary, filed on 21/08/2017, the jurisdiction wag again reverted back to ITO Wd 12(2), Hyderabad. As per the order u/s 120 of the I.T. Act, the source of income is used to determine the jurisdiction. It is pot material what

NUZIVEEDU SEEDS LIMITED,R.R.DIST. vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-16(1), HYDERABAD

In the result, all the appeals under consideration are treated as allowed for statistical purposes in above terms

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

businesses and during survey operations conducted on 31.1.2008 by the respondent - Department, in respect of one G.Sanjeeva Reddy, who is said to be a partner of M/s S.V. Constructions, an agreement of sale was found, as per which, the petitioner was found to have individually paid an amount of RS.1,22,50,000/-, out of RsA.9Iakhs, for purchase of landed

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD vs. NUZIVEEDU SEEDS LIMITED, R.R. DIST, HYDERABAD

In the result, all the appeals under consideration are treated as allowed for statistical purposes in above terms

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

businesses and during survey operations conducted on 31.1.2008 by the respondent - Department, in respect of one G.Sanjeeva Reddy, who is said to be a partner of M/s S.V. Constructions, an agreement of sale was found, as per which, the petitioner was found to have individually paid an amount of RS.1,22,50,000/-, out of RsA.9Iakhs, for purchase of landed