DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

carry forward of losses by filing a revised return of income. 22) Supreme Court held that S. 1 OB (8) of the Act requires exercise of the option within the period prescribed u/s 139(1) of the Act and such time limit is mandatory. The relevant extract of the Supreme Court decision is also reproduced below; “9. Therefore, claiming benefit

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

loss to be carried forward in A.Y 2006-07, the learned CIT invoked the provisions of section 263. Under these circumstances, the Hon'ble High Court has observed as under: “The non obstante clause at the beginning of Section 153A (1) of the Act suspends, for the purpose and to the extent as indicated in such provision, the operation

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

loss to be carried forward in A.Y 2006-07, the learned CIT invoked the provisions of section 263. Under these circumstances, the Hon'ble High Court has observed as under: “The non obstante clause at the beginning of Section 153A (1) of the Act suspends, for the purpose and to the extent as indicated in such provision, the operation

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

loss to be carried forward in A.Y 2006-07, the learned CIT invoked the provisions of section 263. Under these circumstances, the Hon'ble High Court has observed as under: “The non obstante clause at the beginning of Section 153A (1) of the Act suspends, for the purpose and to the extent as indicated in such provision, the operation

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

forward loss of Rs. 27,58,236/-. 5. The AO observed that the information available on record revealed that the assessee company had contractual receipts of Rs. 3,20,42,152/- on which tax was deducted at source (TDS) under section 194C of the Act. As the assessee company had failed to come forth with any details regarding the subject

VANASOWRABHA ASSOCIATES,WARANGAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, WARANGAL

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

Bench: Shri Laliet Kumar & Shri Manjunatha G

loss determine in pursuance of such a return could be denied to be carried forward and set off? The department's contention is that recourse to section 148 is a remedy available to the department to assess or reassess

MADHUSUDAN REDDY PASHAM,HYDERABAD vs. ACIT, CIRCLE-9(1), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Manjunatha G & Shri Ravish Sood

carry forward of loss of Rs. 3,35,01,000/-. Since the additions made by the A.O. on account of unexplained cash credits have already been deleted while adjudicating grounds nos. 15 to 18, the returned loss as claimed by the assessee stands restored. Accordingly, this ground becomes consequential and does not require any separate adjudication. 58. In the result

MADHUSUDAN REDDY PASHAM,HYDERABAD vs. ACIT, CIRCLE-9(1),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Manjunatha G & Shri Ravish Sood

carry forward of loss of Rs. 3,35,01,000/-. Since the additions made by the A.O. on account of unexplained cash credits have already been deleted while adjudicating grounds nos. 15 to 18, the returned loss as claimed by the assessee stands restored. Accordingly, this ground becomes consequential and does not require any separate adjudication. 58. In the result

MADHUSUDAN REDDY PASHAM,HYDERABAD vs. ACIT, CIRCLE-9(1),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Manjunatha G & Shri Ravish Sood

carry forward of loss of Rs. 3,35,01,000/-. Since the additions made by the A.O. on account of unexplained cash credits have already been deleted while adjudicating grounds nos. 15 to 18, the returned loss as claimed by the assessee stands restored. Accordingly, this ground becomes consequential and does not require any separate adjudication. 58. In the result

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business

KASUSALYA AVENUES PRIVATE LIMITED ,KARIMNAGAR vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

forward to work-in-progress amounting to Rs.67,85,773/- under Section 36(1)(iii) of the Income Tax Act, 1961. 8. The assessee carried the matter in appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that the interest paid on customers' advance is wholly and exclusively incurred for the purpose of business

ANANTHA PVC PIPES PRIVATE LIMITED,ANANTAPUR vs. ACIT., CIRCLE-1, KURNOOL

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.317/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) M/S. Anantha Pvc Pipes Pvt. Ltd., Asst. Commissioner Of Income Tax, Vs. Circle-1, Kurnool. Anantapur. Pan:Aagca0936J (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri T. Rajendra Prasad, C.A. & Shri P. Rosi Reddy, Advocate. रधजस् व द्वधरध/Revenue By:: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 31/07/2025 घोर्णध की तधरीख/Pronouncement: 06/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Anantha Pvc Pipes Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 25.07.2024 For The A.Y. 2017-18. 2. At The Outset, It Is Observed That There Is A Delay Of 147 Days In Filing The Present Appeal Before The Tribunal. In This Regard, The

carry ITA No.317/Hyd/2025 6 forward of business loss was denied. Later on, the case was selected for scrutiny under section 143(3) of the Act for verification of cash deposits during demonetisation. The assessee submitted various records including audited balance sheet, cash book, sales invoices, excise documents, and bank statements. However, the Learned Assessing Officer (“Ld. AO”) dropped the proceedings

TMEIC INDUSTRIAL SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 2(1), HYDERABAD

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.898/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) M/S. Tmeic Industrial Vs. Dy.Cit Systems India Private Limited Circle 2(1) Hyderabad Hyderabad Pan: Aadct5493J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.As, K. C. Devdas, Kranthi Palivela & Mrudulatha राज" व "ारा/Revenue By: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 08/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

carried forward business losses to offset the adjustment made, resulting in no payable demand. 3. Any other ground or grounds that may be urged at the time of hearing” 4. The Learned Authorized Representative (“Ld. AR”) submitted that the grounds raised in the additional ground are purely legal in nature and do not require investigation of any fresh facts

PRYSMIAN CAVI E SISTEMI S.R.L,HYDERABAD vs. DCIT (INT,TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

carried on with own capital and not with borrowed\ncapital has been ignored by the Income-tax Officer, there may not\nhave been any difficulty in upholding that order. But, when he\nproposes to add back an exact item in the profit and loss account,\nhe was relying on the rejected books which he could not do as held

PRYSMIAN CAVI E SISTEMI SRL INDIA PROJECT OFFICE (FORMERLY PIRELLI CAVI SISTEMI S P A INDIA PROJECT OFFICE),HYDERABAD vs. DCIT,( INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

reassessment order dated 20.12.2006 under\nsection 143(3) r.w.s.147 of the Act was adjudicated separately by the Tribunal\nvide order dated 30.11.2015. In that order, the Tribunal directed the Assessing\nOfficer to delete the addition made in respect of offshore contract receipts;\nestimate the income at 10% of the onshore contract works / services receipts;\nand specifically directed not to consider

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 :

forward unabsorbed depreciation and loss of amalgamating company would be allowed from the appointed date itself. The relevant extracts are reproduced below: "13 .... However, the moment the scheme was sanctioned as per the decision of Supreme Court in case of Marshall Sons & Co. (India) Ltd. (supra), it would relate back to the appointed date as envisaged under the scheme unless