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

reassessment. Section 292 BB of the Act cannot obviate the requirement of complying with a jurisdictional condition. For the Assessing Officer to make an order of assessment under Section 143 (3) of the Act} it is necessary to issue a notice under Section 143 (2) of the Act and in the absence of a notice under Section 143(2

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 :

section 147 / 148 of the Act, the coordinate Bench had held as under : “22. Coming back to our point we have to examine whether protective assessment/addition is possible under section 147 in respect of the same person and for the same period. When a regular assessment is made and later on it comes to the notice of the Assessing Officer

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

In the result, the appeal of assessee in ITA No

12,58,20,688\n2021-22 | 5,57,69,012 | 1,62,07,177 | 58,57,556 | 41,70,416 | 3,24,22,875 | 9,03,945 | 11,53,30,981\nTotal | 45,52,39,617 | 18,45,03,085 | 4,39,01,458 | 2

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

12,58,20,688 |\n| 2021-22 | 5,57,69,012 | 1,62,07,177 | 58,57,556 | 41,70,416 | 3,24,22,875 | 9,03,945 | 11,53,30,981 |\n| Total | 45,52,39,617 | 18,45,03,085 | 4,39,01,458 | 2

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

Bench: Us:

12 Sanghi Textiles Privarte Limited vs. ITO where the return of income had been furnished by the assessee under section 139 of the Act, or in response to a notice under sub-section (1) of section 142 of the Act. The Ld. AR submitted that as the assessment in the present case was framed under section 147 r.w.s 144B

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

12. We have thoughtfully considered the contentions advanced by the Ld. Authorized Representatives of both parties regarding the validity of the order passed under Section 147 of the Act, dated 26/03/2025, based on the Notice issued under Section 148 of the Act, dated Prabhakar Reddy Basireddy vs. DCIT 29/11/2023, by the ACIT, Central Circle 1(1), Hyderabad (copy placed

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

12. We have thoughtfully considered the contentions advanced by the Ld. Authorized Representatives of both parties regarding the validity of the order passed under Section 147 of the Act, dated 26/03/2025, based on the Notice issued under Section 148 of the Act, dated Prabhakar Reddy Basireddy vs. DCIT 29/11/2023, by the ACIT, Central Circle 1(1), Hyderabad (copy placed

KRISHNAVENI KOKKULA,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

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

Bench: Us:

12 Krishnaveni Kokkula vs. ITO section (2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have

ANKIT JAIN,HYDERABAD. vs. ACIT., CENTRAL CIRCLE - 1(2), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

12. We have thoughtfully considered the contentions advanced by the Ld. Authorized Representatives of both parties regarding the validity of the order passed under Section 143(3) r.w.s 147 of the Act, dated 11/12/2024, based on the Notice issued under Section 148 of the Act, Ankit Jain vs. ACIT/DCIT dated 11/04/2023 by the DCIT, Central Circle 1(2), Hyderabad (copy

ANKIT JAIN, HYDERABAD. vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD.

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

12. We have thoughtfully considered the contentions advanced by the Ld. Authorized Representatives of both parties regarding the validity of the order passed under Section 143(3) r.w.s 147 of the Act, dated 11/12/2024, based on the Notice issued under Section 148 of the Act, Ankit Jain vs. ACIT/DCIT dated 11/04/2023 by the DCIT, Central Circle 1(2), Hyderabad (copy

RASHID HUSSAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(3), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

2) of Section 153C. To sum up, the obligation cast upon an assessee to call in question the jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where he objects to the assumption of jurisdiction by the A.O, and not otherwise. 17. Before proceeding further, it would be relevant

THE OOKAL FARMERS SERVICE COOPERATIVE SOCIETY LIMITED,WARANGAL vs. ITO., WARD-1, WARANGAL

In the result, all three appeals of the assesssee, i

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

12. Shri SNSR Chinmai, Advocate, the Ld. AR, submitted that both the impugned order passed under Section 148A(d) of the Act, dated 24.04.2022 and Notice under Section 148 of the Act, dated 25.04.2022 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 151A

THE OOKAL FARMERS SERVICE COOPERATIVE SOCIETY LIMITED,WARANGAL vs. ITO., WARD-1, WARANGAL

In the result, all three appeals of the assesssee, i

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

12. Shri SNSR Chinmai, Advocate, the Ld. AR, submitted that both the impugned order passed under Section 148A(d) of the Act, dated 24.04.2022 and Notice under Section 148 of the Act, dated 25.04.2022 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 151A

THE OOKAL FARMERS SERVICE COOPERATIVE SOCIETY LIMITED,WARANGAL vs. ITO., WARD-1, WARANGAL

In the result, all three appeals of the assesssee, i

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

12. Shri SNSR Chinmai, Advocate, the Ld. AR, submitted that both the impugned order passed under Section 148A(d) of the Act, dated 24.04.2022 and Notice under Section 148 of the Act, dated 25.04.2022 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 151A

MADURAI TUTICORIN EXPRESSWAYS LIMITED,HYDERABAD vs. ACIT., CIRCLE - 5(1), HYDERABAD

In the result, all three appeals of the assesssee, i

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

12. Shri SNSR Chinmai, Advocate, the Ld. AR, submitted that both the impugned order passed under Section 148A(d) of the Act, dated 24.04.2022 and Notice under Section 148 of the Act, dated 25.04.2022 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 151A

VENKATA RAMANAMMA SAKAMURI,MARRIPADU, NELLORE vs. ITO., WARD-1, NELLORE

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

Bench: Us:

12. Per Contra, the Ld. Senior Departmental Representative (Ld. Sr. DR), submitted that as the assessee within the specified time period contemplated under sub-section (3) of Section 124 of the Act, i.e. within a period of one month from the date on which the said notice was served upon him had not called in question the jurisdiction

RAGHU ALEKH BARLI,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

reassess is limited and based on the fulfilment of certain preconditions. (CIT v. Kelvinator of India Ltd.)" (emphasis supplied by us) 21. We shall now advert to the judgment of the Hon'ble Supreme Court, in the case of Deputy Commissioner of Income-tax (Exemption) v. Kalinga Institute of Industrial Technology [2023] 454 ITR 582 (SC), that has been relied

LINGAMGUNTA ADILAXMI,SECUNDERABAD vs. ITO., WARD-10(1), HYDERABAD

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

reassess is limited and based on the fulfilment of certain preconditions. (CIT v. Kelvinator of India Ltd.)" (emphasis supplied by us) 21. We shall now advert to the judgment of the Hon'ble Supreme Court, in the case of Deputy Commissioner of Income-tax (Exemption) v. Kalinga Institute of Industrial Technology [2023] 454 ITR 582 (SC), that has been relied

BIKARAM PUSHPENDER,HYDERABAD vs. ITO, WARD-9(1), HYDERABAD

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

reassess is limited and based on the fulfilment of certain preconditions. (CIT v. Kelvinator of India Ltd.)" (emphasis supplied by us) 21. We shall now advert to the judgment of the Hon'ble Supreme Court, in the case of Deputy Commissioner of Income-tax (Exemption) v. Kalinga Institute of Industrial Technology [2023] 454 ITR 582 (SC), that has been relied