INDUKURI SUNDARI, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeals of both assessee’s are allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blesmt Indukuri Sundari V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aakpi8049P (Appellant) (Respondent) Shri Indukuri Syam Prasad Reddy V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aadpi1621C (Appellant) (Respondent) : Shri Mohammad Afzal Assessee By Department By : Shri M.V.S.T. Sai

reassessment 11 ITA NO. 645 & 646/HYD/2017 (A.Y: 2008-09) Smt Indukuri Sundari Shri Indukuri Syam Prasad Reddy can be made in consequent to order u/s 263 after 31.03.2014, therefore, the order made on 27.02.2015, u/s 143(3) r.w.s 263 is barred by limitation. Therefore, the same is to be held as null and void. 14. Learned Counsel for the assessee

JVR RETAILS PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE -2(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2012-13 Jvr Retails Private Limited Vs Dcit, Circle-2(1) C/O. Murali & Co. . Hyderabad Chartered Accountants 6-3-655/2/3, Somajiguda Hyderabad-500 082 Pan : Aaccv9428J (Appellant) (Respondent) Assessee By: Shri M.V.Joshi Appeared For P.Murali Mohan Rao, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.01.2023 Date Of Pronouncement: 31.01.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.03.2021 Passed U/S. 263 By The Learned Principal Commissioner Of Income Tax -2, Hyderabad Relating To A Y 2012-13. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Domestic Company Engaged In The Business Of Retails & Manufacturing Of Jewelry. It Filed Its Return Of Income Declaring Total Income Of Rs. 49,97,390/- On 08.09.2012 Which Was Processed U/S 143(1) On 21.02.2013. Subsequently, The Ao Reopened The Assessment By Recording Reasons As Per Provisions Of Section 147. The Reasons To Believe Which Was Put Up Before The Ld.Pcit-2 For Approval & Which Has Been Reproduced By The Ao In The Body Of The Assessment Order Read As Under:-

u/s. 263 of the I.T.Act to revise reassessment order u/s. 147 of the I.T.Act to bring certain items liable to tax which

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

263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring to the decision

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

263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring to the decision

MSN INSTITUTE OF MEDICAL SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

263 with\nregard to the issue of unexplained investment in the\npurchase of lands at Rangareddyguda, though such\nassessment order cannot be regarded as erroneous\nwhen the Assessing Officer has taken one of the\nplausible views by assessing the same income in the\nassessment order passed u/s 153C for A.Y 2020-21.\n6. On the facts and facts and circumstances

PRATHIMA RESORTS & RESTAURANTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

263 with\nregard to the issue of unexplained investment in the\npurchase of lands at Rangareddyguda, though such\nassessment order cannot be regarded as erroneous\nwhen the Assessing Officer has taken one of the\nplausible views by assessing the same income in the\nassessment order passed u/s 153C for A.Y 2020-21.\n6. On the facts and facts and circumstances

PRAYAGA GREEN MEADOWS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Kodangal, though such 4 ITA.Nos.1333, 1331 & 1328/Hyd./2024 assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C

ADRIJA FARMS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Kodangal, though such 4 ITA.Nos.1333, 1331 & 1328/Hyd./2024 assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C

DAKSHAYANI HORTICULTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Kodangal, though such 4 ITA.Nos.1333, 1331 & 1328/Hyd./2024 assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C

SPARK VIDYUTH PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Rangareddyguda, though such assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C for A.Y 2020-21. 6. On the facts and facts and circumstances

PRATHIMA EGGSEL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Rangareddyguda, though such assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C for A.Y 2020-21. 6. On the facts and facts and circumstances

PRATHIMA EGGSEL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Rangareddyguda, though such assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C for A.Y 2020-21. 6. On the facts and facts and circumstances

MSN INSTITUTE OF MEDICAL SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Rangareddyguda, though such assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C for A.Y 2020-21. 6. On the facts and facts and circumstances

PRATHIMA RESORTS & RESTAURANTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

263 with regard to the issue of unexplained investment in the purchase of lands at Rangareddyguda, though such assessment order cannot be regarded as erroneous when the Assessing Officer has taken one of the plausible views by assessing the same income in the assessment order passed u/s 153C for A.Y 2020-21. 6. On the facts and facts and circumstances

SPARK VIDYUTH PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

263 with\nregard to the issue of unexplained investment in the\npurchase of lands at Rangareddyguda, though such\nassessment order cannot be regarded as erroneous\nwhen the Assessing Officer has taken one of the\nplausible views by assessing the same income in the\nassessment order passed u/s 153C for A.Y 2020-21.\n6. On the facts and facts and circumstances

UNITED ELECTRIC CO., ,CHIRALA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal filed by the assessee is dismissed

revision proceedings u/s 263 the assessee argued before the CIT that the assessment was completed on agreed basis but did not challenge estimation of income @ 8%. The Hon’ble ITAT has confirmed the order of the Ld.CIT and given an observation that the A.O shall consider the all the facts and circumstances of the case and estimate the income

SRI EDUPAYALA VANA DURGA BHAVANI,HYDERABAD vs. INCOME TAX OFFICER, WARD-1, SANGAREDDY

Bench: Us:

u/s 147 of the IT Act estimating the income @ 8% on gross receipts of Rs. 2.48 crores. 4. The PCIT's erred in issuing show cause notice dated 13/12/2023 findings that the original assessment order was erroneous and prejudicial to the interests of the Revenue are arbitrary, perverse, and based on mere conjectures and surmises. 5. The directions issued

INCOME TAX OFFICER, WARD-1, ADONI vs. T RAMA SUBBA REDDY , ADONI

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment held that the total consideration on sale of land was Rs.4,67,20,000/- and not Rs.21.75,000/- as adopted by him in the regular assessment and allowed cost of acquisition of Rs.21,54,067/- without allowing any other claims made by the assessee and passed assessment order on 31.03.2016 u/s 143(3) r.w.s. 263 of the Act interalia

MYLAN LABORATORIES LTD,(BEING THE AMALGAMATED COMPANY OF ASTRIX LABORATORIES LIMITED), HYD HYD,HYDERABAD vs. DCIT, CIRCLE-16(2), HYD, HYDERABAD

In the result, the appeal of Assessee is allowed and the appeal of Revenue is dismissed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

reassessment proceedings. He applied the analogy relating to AY. 2006-07 i.e adopting the value of DMFs and Technical know-how as Nil in the hands of the assessee. 2.5. AO passed an order u/s 143(3) r.w.s 147 of the Act dt. 30-08-2013. Being aggrieved by the said order, assessee preferred an appeal before