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

155 ITR 166(SC). In this case, the Court has observed that Section 37(2) provides that "the provisions of the Code relating to searches, shall so far as may be, apply to searches directed under Section 37(2). Reading the two sections together it merely means that the methodology prescribed for carrying out the search provided in Section

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,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

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

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)

155(20) of the Act and therefore it amounts to impossibility of performance. 3.5 The Assessment Order passed by the Ld. AO is erroneous and bad in law as much as the Ld. AO has passed the order without considering the submissions and prevailing judicial precedents made during the course of hearing. Grounds relating to Transfer Pricing ('TP') matters

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

reassess the income of the other person in accordance\nwith the provisions of section 153A, if, that Assessing Officer is satisfied that the books\nof account or documents or assets seized or requisitioned have a bearing on the\ndetermination of the total income of such other person for six assessment years\nimmediately preceding the assessment year relevant to the previous

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

LATE RAJASEKHAR CHELIKANI,HYDERABAD vs. ACIT., CENTRAL CIRCLE 3(2), HYDERABAD

Bench: Us:

155 (Mad), had reiterated the aforesaid view and observed that the notice issued on a dead person is invalid and cannot be enforced. Further, we find that the Hon'ble High Court of Bombay in the case of Sumit Balkrishna Gupta Vs. ACIT (2019) 103 taxmann.com 188 (Mum), had observed that the requirement of issuing notice to a correct person

ACIT, CENTRAL CIRCLE - 2(2), HYDERABAD vs. AMR INDIA LIMITED, HYDERABAD

In the result, Cross Objection No

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

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

ACIT, CENTRAL CIRCLE - 2(2), HYDERABAD vs. AMR INDIA LIMITED, HYDERABAD

In the result, Cross Objection No

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

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

ASHWITHA REDDY BADDAM,NIZAMABAD vs. INCOME TAX OFFICER, WARD-2, NIZAMABAD

In the result, the appeals filed by the assessee are allowed\nfor the A

155/- and\nassessee's share of 1/3rd works out to Rs.2,01,030/-. The A.O.\nafter noting the relevant capital gain, computed by the assessee\nand also taking into consideration, the facts of the case, issued\nshow cause notice and called upon the assessee to explain as to\nwhy the cost of acquisition of undivided portion of land shall

S HARINATH CHOWDARY ,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(1), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi

155 sq.feet consisting of 2 6 flats. The flats were handed over to the assessee in the FY 2005-06 and subsequent sale of flats to prospective buyers took place in the financial years 2005-06 and 2006-07. During the assessment of the assessee for the AY 2007-08, the A.O. made an addition of Rs.51

M/S VINSRI INFOTECH,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-9(1), HYDERABAD

In the result, assessee’s appeal is partly allowed and the revenue’s appeal is dismissed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyblock Period: 1996-97 To 2001-2002 M/S Vinsri Infotech, Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 9(1), Hyderabad. Pan – Aabfv6806E Appellant Respondent & Block Period: 1996-97 To 2001-2002 Dy. Commissioner Of Vs. M/S Vinsri Infotech, Income-Tax, Circle – Hyderabad. 9(1), Hyderabad Pan – Aabfv 6806 E Appellant Respondent Assessee By: Shri Y. Ratnakar Revenue By: Shri Sunku Srinivasu Date Of Hearing: 19/09/2019 Date Of Pronouncement: 04/12/2019 O R D E R Per P. Madhavi Devi, J.M.:

Section 27IB of the IT Act. The appellant being aggrieved of the assessment preferred an appeal before the Honourable Commissioner (Appeals) of Income Tax. The Commissioner (Appeals) of Income. Tax, Guntur, has passed the orders setting aside the assessments made by the Assessing Officer and in favour of the assessee on 28-04-2011. Thereafter the department filed an appeal