PACC CONTAINER LINE PTE LIMITED,NELLOR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO ,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION) , NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect

PRYSMIAN CAVI E SISTEMI S.R.L,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

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

INCOME TAX OFFICER, WARD-1, NELLORE vs. VENKATA RAMANAMMA SAKAMURI, NELLORE

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

Bench: Us:

154 taxmann.com 159/457 ITR 647 (Bombay), held that where the Assessing Officer issued a reopening notice beyond the period of three years, approval was required to be taken as per provisions of amended section 151 from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. The relevant observations of the Hon'ble High Court

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 :

154 and Explanation 1 (f) to section 115JB being squarely covered, the same cannot be found fault with. We are of the considered view that the Miscellaneous Petition filed by the revenue under section 254(2) of the Act was wholly misconstrued. The Tribunal has distinguished the case of Sobha Developers (supra) relied upon by the revenue with VireetInvestment

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

154\nTaxmann.com 193 and the decision of the Hon'ble Delhi High\nCourt in the case of Divya Capital One Pvt. Ltd vs. Assistant\nCommissioner of Income Tax (TS-5518-HC-2022(DELHI)-O). The\nassessee had also relied upon the decision of the Hon'ble\nKarnataka High Court in the case of Smt. Vasanthi Ramdas Pai\nvs. Income

VIJAYARAGHAVAN LAKSHMI,,CHENNAI vs. ACIT, CIRCLE-1(2), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2016-17 Mrs. Vijayaraghavan Vs. Acit, Central Circle-1(2) Lakshmi Aaykar Bhawan Ground Floor, Block-A Opp:L.B.Stadium Prince Villa, New No.15 Basheerbagh Rajamannar Street Hyderabad Teynampet Chennai-600 018 Tamilnadu

section 154 were also brought to the notice of the ld.CIT(A). 3 ITA 260/Hyd/2022 4. However, the ld.CIT(A) was not satisfied with the arguments advanced by the assessee and upheld the 154 order passed by the AO by observing as under:- 6. In the instant case, notice u/s. 153A was issued to the appellant and no return

RAMESH BABU BEJJALA,KOTHAGUDEM vs. INCOME TAX OFFICER, WARD-1, KOTHAGUDEM

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

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

reassessment order are vitiated in lew. 3. The learned CIT(A) erred in confirming the addition of Rs. 30,17,000/- made under Section 63A of the Act by the Assessing Officer without any independent verification or reconciliation. The authorities failed to refute the explanations provided with cogent evidence rendering the addition unsustainable. 4. The learned CIT(A) failed

NAVDURGA TRANSPORT COMPANY,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(1), HYDERABAD

Appeal is allowed in terms of our aforesaid observations

Bench: Us:

reassessment proceedings, we are 7 ITA 218 and 219/Hyd/2025 Navadurga Transport Company vs. ITO unable to persuade ourselves to accept the same. As observed by the CIT(A) and rightly so, as the AO at the stage of initiation of proceedings under section 147 of the Act is only required to have some material available with him, based on which

NAVDURGA TRANSPORT COMPANY,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(1), HYDERABAD

Appeal is allowed in terms of our aforesaid observations

Bench: Us:

reassessment proceedings, we are 7 ITA 218 and 219/Hyd/2025 Navadurga Transport Company vs. ITO unable to persuade ourselves to accept the same. As observed by the CIT(A) and rightly so, as the AO at the stage of initiation of proceedings under section 147 of the Act is only required to have some material available with him, based on which

INTERWRAP CORP PRIVATE LIMITED (SUCCESSOR OF OWENS CORNING INDUSTRIES (INDIA) PRIVATE LIMITED),MUMBAI vs. DCIT., CIRCLE -5(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON'BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

154 was passed on 19.08.2021, revising the purchase adjustment to Rs. 49,86,32,000/-. 6. Thereafter, the A.O. passed a draft assessment order under Section 143(3) r.w.s. 144C(1) of the Act on 21.09.2021, determining the total income at Rs. 69,97,35,729/-, by incorporating the above transfer pricing adjustments. Aggrieved, the assessee filed objections before

SUDHA DOSHI,HYDERABAD vs. ITO - WARD 5(1), HYDERABAD

154 of the Act\non the same issue, it cannot be made. The attention of this Court\nhas been drawn to the notice dated 20.01.2022 issued for\nrectification of mistake and the order under Section 148A(d) of\nthe Act passed on 22.04.2024. Reliance has been placed on the\nfollowing decisions rendered by the Apex Court in Union of India

VICTORY ELECTRICALS LIMITED, MEDCHAL,R.R.DIST vs. DCIT, CIRCLE-17(2), HYDERABAD, HYDERABAD

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2012-13 Victory Electricals Ltd., V Dcit,Circle-17(2) Plot No.8, Survey No.855, S. Signature Towers Ida, Medchal, Kondapur Ranga Reddy, Hyderabad Hyderabad-501 401

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154

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

In the result, the C.O. filed by the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

154-172] (i) ITOV Virat Credit and Housing (P) Ltd, ITAT, (Del) ITA-89/Del/2012 (order Dt 9/2/2018) I Pages-154-172 (ii) S. Goyendra lime chemical Ltd -231 Taxman 73 (MP) (iii) Central India Electric Supply Co Ltd V ITO 51 DTR 51 7.6 No full Satisfaction by AO:- :- 9 -: ITA No.. 497/Hyd/2019 and CO 16/H/2019 Coastal Projects

RR MARKETING,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

154 of the Act\non the same issue, it cannot be made. The attention of this Court\nhas been drawn to the notice dated 20.01.2022 issued for\nrectification of mistake and the order under Section 148A(d) of\nthe Act passed on 22.04.2024. Reliance has been placed on the\nfollowing decisions rendered by the Apex Court in Union of India