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

192 Taxman 197 and CIT v. Salarpur Cold Storage (P.) Ltd. [2014] 50 taxmann.com 105/(2015) 228 Taxman. 7/15/2019 www.taxmann.com. 6/7 48 (All.) (Mag.) and the decision of the Madras High Court in Sapthagiri Finance & Investments v. ITA /2012j 25 taxmann.com 341/210 Taxman 78 (Mag.), that Section 292 BB of the Act would apply insofar as failure of 'service

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU , HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment of escaped income, and which he intends to take into account, he would be required to issue a fresh notice under section 148. 19. In the present case, as is noted above, the Assessing Officer was satisfied with the justifications given by the assessee regarding the items viz., club fees, gifts and presents and provision for leave encashment

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment of escaped income, and which he intends to take into account, he would be required to issue a fresh notice under section 148. 19. In the present case, as is noted above, the Assessing Officer was satisfied with the justifications given by the assessee regarding the items viz., club fees, gifts and presents and provision for leave encashment

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

192 (Bombay). b) Erred in upholding the flawed approach adopted by the Ld. AO in not granting deduction under section 10A of the Act which was allowed in the subsequent year i.e., AY 2006-07 by the Ld. AO, during the regular assessment proceedings under section 143(3) of the Act. 7. Erred in upholding the action

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

Bench: Us:

reassessment was within the prescribed time and squarely falls within the framework of section 147, Therefore, the action of the AO in reopening the assessment is held to be valid and in accordance with law. Accordingly, grounds of appeal pertaining to this issue are dismissed and not allowed. 5.2. The appellant has challenged against the addition

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

192 (AP & TS). (b) Cooper Corporation Pvt Ltd., Vs DCIT, reported in ITA No. 866/PN/2014. (c) CIT Vs Woodward Governor India Pvt Ltd., reported 179 taxman.com 326 (SC) (d) Gati Limited Vs ITO, in ITA No. 1325/Hyd/2015. (e) Crane Software International Ltd., Vs. DCIT in ITA No. 741/Ban/2010. 6.2 The Ld. DR, on the other hand, supported the orders

KARTHIK KUMAR KYATHAM,NIZAMABAD vs. ITO, WARD-1, ADILABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1658/Hyd/2025

192) WIPRO LIMITED 12 Amount paid or credited 904142 TDS-192 2. The assesse has filed return of income declaring income from salary (Gross salary Rs.9,04,142). Further, the assesse has declared loss from house property with claim of interest payable on borrowed capital of Rs.79,577. Hence, the above mentioned information suggests that purchase consideration of Rs.31

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. ABIR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the revenue is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Asst. Commissioner Of Vs. Abir Infrastructure Pvt. Income-Tax, Ltd., Hyderabad. Central Circle – 1(3), Hyderabad. Pan – Aafc3608N (Appellant) (Respondent)

reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section, or recomputed the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned(hereinafter in this section and in sections

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

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

reassess the total income of the assessee, provided the Assessing Officer has in his possession books of accounts or other documents or evidence which reveal that the income, represented in the form of “asset”, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more in the relevant assessment year or in aggregate

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

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

reassess the total income of the assessee, provided the Assessing Officer has in his possession books of accounts or other documents or evidence which reveal that the income, represented in the form of “asset”, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more in the relevant assessment year or in aggregate

VINOD OJHA,HYDERABAD vs. INCOME TAX OFFICER, WARD-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1231/Hyd/2024 (िनधा"रण वष"/Assessment Year 2016-2017) Vinod Ojha, The Income Tax Officer, Ward-5(1), Hyderabad-500012. Vs. Hyderabad – 500 057. Telangana. Telangana. Pan Aahpo3171F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Kumar Pal Tated राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr

section 148A(d) of the Act after obtaining the approval of the Principal CIT-1, Mumbai vide letter dated 15/07/2022, we are of the considered view that the Revenue has not followed the mandatory provisions of the Act while initiating the reassessment proceedings and sanction of the Specified Authority is not in conformity with the law prevalent at the time

OLECTRA GREENTECH LIMITED ,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-3(2), HYDERABAD

In the result, both the appeals of the assessee are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

OLECTRA GREENTECH LIMITED ,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-3(2), HYDERABAD

In the result, both the appeals of the assessee are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

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

192 (SC). 10 M/s. HES Infra Pvt. Ltd. 9.1. Further, it was the contention of the ld.AR that the decision of Hon’ble Mumbai High Court in the case of EBR Enterprises (supra) related to section 264 of the Act whereby the Hon’ble Bombay High Court had held that the assessee cannot revise the return and claim the benefit

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

192 (SC). 10 M/s. HES Infra Pvt. Ltd. 9.1. Further, it was the contention of the ld.AR that the decision of Hon’ble Mumbai High Court in the case of EBR Enterprises (supra) related to section 264 of the Act whereby the Hon’ble Bombay High Court had held that the assessee cannot revise the return and claim the benefit

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

192 (SC). 10 M/s. HES Infra Pvt. Ltd. 9.1. Further, it was the contention of the ld.AR that the decision of Hon’ble Mumbai High Court in the case of EBR Enterprises (supra) related to section 264 of the Act whereby the Hon’ble Bombay High Court had held that the assessee cannot revise the return and claim the benefit

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

192 (SC). 10 M/s. HES Infra Pvt. Ltd. 9.1. Further, it was the contention of the ld.AR that the decision of Hon’ble Mumbai High Court in the case of EBR Enterprises (supra) related to section 264 of the Act whereby the Hon’ble Bombay High Court had held that the assessee cannot revise the return and claim the benefit

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

SUDHAKER MUNIGETI,ADILABAD vs. ITO., WARD-1, ADILABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.471/Hyd/2025 Assessment Years – 2019-2020 Sudhaker Munigeti, The Income Tax Officer, Vs. Adilabad – 504 001. Ward-1, Telangana. Adilabad. Pan Acapm9247K Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca, A Srinivas राज" व "ारा /Revenue By: Ms Malathi B. Sr. Ar

192 3 ITA.No.471/Hyd./2025 7. The Appellate Commissioner ought to have noticed that, the first notice issued under section 143(2) and the second notice issued under section 143(2) differ on the nature of income escaping assessment, and as such has been issued without application of mind and needs to be quashed 8. Without prejudice to the above