ASST. DIRECTOR OF INCOME-TAX (INTL.TXN)-II,, HYDERABAD vs. M/S MIDWEST GRANITE (P) LIMITED,, HYDERABAD

Accordingly, the assessee’s appeal for the A.Y. 2009-10 is dismissed as withdrawn”

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

163. In other words, what is brought to tax in the hands of the Petitioner is the capital gains which are stated to accrue to the Bermudian company. The provisions of Section 1 53(B) would therefore clearly not have any application. The judgment of the Supreme Court in Claggett Brachi

ASST. DIRECTOR OF INCOME-TAX (INTL.TXN)-II,, HYDERABAD vs. M/S MIDWEST GRANITE (P) LIMITED,, HYDERABAD

Accordingly, the assessee’s appeal for the A.Y. 2009-10 is dismissed as withdrawn”

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

163. In other words, what is brought to tax in the hands of the Petitioner is the capital gains which are stated to accrue to the Bermudian company. The provisions of Section 1 53(B) would therefore clearly not have any application. The judgment of the Supreme Court in Claggett Brachi

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)

1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident under section 163 and the assessment, reassessment

SUDHEER PARIMALA,HYDERABAD vs. INCOME TAX OFFICER, WARD-10(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.758/Hyd./2025 Assessment Year 2015-2016 Sudheer Parimala, The Income Tax Officer, Hyderabad – 500 016. Vs. Ward-10(1), Hyderabad. Pan Ahppp7572E Pin - 500 004. Telangana (Appellant) (Respondent) For Assessee : Ca Kranthi Palivela & Ca Mrudulatha For Revenue : Dr. Sachin Kumar, Sr. Ar Date Of Hearing : 24.03.2026 Date Of Pronouncement : 17.04.2026 आदेश/Order

1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be treated as the agent of a non-resident under section 163 and the assessment, reassessment

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

section 148 of the Act. Actual date of service of notice through mail. J 29.07.2022 Then the notice is barred by [para 114(h) of K = H-J 45 Rajeev Bansal. 6. Thus, the learned Authorised Representative of the Assessee has submitted that the notice issued u/sec.148 for the assessment year 2016-2017 is invalid and liable to be quashed

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

The appeal of the Assessee is allowed on this ground alone

163 (SC). In the case of Kulwant Singh vs. Union of India the Hon'ble Punjab & Haryana High Court_in Civil WP.No.18032 of 2024 etc., after considering the Judgment of Hon'ble Supreme Court in the case of Union of India vs. Rajeev Bansal (supra), has quashed the notice issued u/sec.148 beyond the surviving period being barred by limitation

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 of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

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 of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

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 of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

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 of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

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 of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

EXPRESSWAY SERVICES PVT LTD,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

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

1% commission income on total sub-contract works received by the assessee. The Ld. CIT(A) deleted this addition. Although, the assessee challenged findings of the ld. CIT(A) on this issue, it becomes academic, because Expressway Services Pvt. Ltd. finally addition has been fully deleted by the ld. CIT(A). Therefore, we are not going to adjudicate the ground

EXPRESSWAY SERVICES PVT LTD,HYDERABAD vs. DCIT., CENTRAL CIRCLE -2(4), HYDERABAD

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

1% commission income on total sub-contract works received by the assessee. The Ld. CIT(A) deleted this addition. Although, the assessee challenged findings of the ld. CIT(A) on this issue, it becomes academic, because Expressway Services Pvt. Ltd. finally addition has been fully deleted by the ld. CIT(A). Therefore, we are not going to adjudicate the ground

EXPRESSWAY SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

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

1% commission income on total sub-contract works received by the assessee. The Ld. CIT(A) deleted this addition. Although, the assessee challenged findings of the ld. CIT(A) on this issue, it becomes academic, because Expressway Services Pvt. Ltd. finally addition has been fully deleted by the ld. CIT(A). Therefore, we are not going to adjudicate the ground

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

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

reassessment u/s 143(3) rws 2S4 of the LT.Act on 26.03.2014 and rejected the claim for deduction u/s 80IA of the Act. The Assessing Officer in the assessment order mentioned that - a) the entire project is not executed by the assessee and only part of the project was undertaken; b) the infrastructure facility was not operated by the assessee

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

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

reassessment u/s 143(3) rws 2S4 of the LT.Act on 26.03.2014 and rejected the claim for deduction u/s 80IA of the Act. The Assessing Officer in the assessment order mentioned that - a) the entire project is not executed by the assessee and only part of the project was undertaken; b) the infrastructure facility was not operated by the assessee

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

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

reassessment u/s 143(3) rws 2S4 of the LT.Act on 26.03.2014 and rejected the claim for deduction u/s 80IA of the Act. The Assessing Officer in the assessment order mentioned that - a) the entire project is not executed by the assessee and only part of the project was undertaken; b) the infrastructure facility was not operated by the assessee

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

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

reassessment u/s 143(3) rws 2S4 of the LT.Act on 26.03.2014 and rejected the claim for deduction u/s 80IA of the Act. The Assessing Officer in the assessment order mentioned that - a) the entire project is not executed by the assessee and only part of the project was undertaken; b) the infrastructure facility was not operated by the assessee

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED ,HYDERABAD vs. INCOME TAX OFFICERS ,WARD -1(2), HYDERABAD

In the result, appeal of the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2012-13 Country Club Hospitality & Vs. Income-Tax Officer, Ward Holidays Ltd., Hyderabad. – 1(2), Hyderabad. Pan – Aaacc 8276 B (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Rohit Mujumdar Date Of Hearing: 08/02/2022 Date Of Pronouncement: 17/02/2022

1. MSEB Holding Co. Ltd., [2020] 113 taxmann.com 163(SC) 2. GB Bros. & Konda Rajagopala Chetty Beedi Factory (P) Ltd., [2003] 132 Taxman 737 (AP) 3. Tns India Pvt. Ltd., ITA No. 515/Hyd/2015. 8. The ld. DR, on the other hand, relied on the orders of lower authorities and submitted that the lower authorities have rightly disallowed the amounts under