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

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

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 no relevance in so far his inherent jurisdiction

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)

4 Rashid Hussain vs. ACIT 16/01/2025 declaring an income of Rs.19,20,130/-. As the return of income filed by the assessee in compliance to the notice issued under section 148 of the Act was beyond the stipulated period of 92 days as was provided in the said notice, therefore, the AO while framing the assessment observed that the same

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:

120 of the Act. Sub-section (2) of Section 124 contemplates the manner in which any controversy regarding the territorial jurisdiction of an AO is to be resolved. Apropos sub-section (3) of Section 124 of the Act, the same places a restriction upon an assessee to call in question the jurisdiction of the A.O where he had initially

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:

120 of the Act. Sub-section (2) of Section 124 contemplates the manner in which any controversy regarding the territorial jurisdiction of an AO is to be resolved. Apropos sub-section (3) of Section 124 of the Act, the same places a restriction upon an assessee to call in question the jurisdiction of the A.O where he had initially

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

RAMESH CHANDRA MAJITHIA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

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

120, 97 and 97 days, respectively. The ld. AR for the assessee has moved a condonation petition explaining reasons thereof. Ld. DR objected for the same. We have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we condone the delay and admit all the appeals for hearing. 2.1 The grounds raised

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

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

120 days acceptable for the\nsoftware development industry for computing notional interest on overdue receivables.\n9. erred in considering the SBI short term deposit rate instead of considering LIBOR rate of interest\nfor computing the notional interest on overdue receivables.\nTP adjustment in relation to payment of interest on ECB by the Appellant to associated\nenterprise

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re- opened

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re- opened

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re- opened

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re- opened

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:

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 no relevance in so far his inherent jurisdiction

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:

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 no relevance in so far his inherent jurisdiction

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)

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 no relevance in so far his inherent jurisdiction

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)

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 no relevance in so far his inherent jurisdiction