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10 results for “reassessment”+ Section 195(1)clear

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Key Topics

Section 1479Section 408Section 14A7Addition to Income6Section 153A5Section 56(2)(viia)4Section 1484Disallowance4Section 143(2)3

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

ITA 332/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

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

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 195(2)Section 40

195(2) of the Act. (b) Not appreciating the submissions made by the Appellant that the payments made to recipient/s are not chargeable to tax in India and accordingly, taxes were not liable to be deducted on the same and have erred in concluding that the Appellant is required to deduct TDS on payment for business support service expenses

Section 143(3)3
Deduction3
Condonation of Delay3

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

ITA 368/HYD/2024[2005-06]Status: DisposedITAT Hyderabad04 Feb 2026AY 2005-06

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

Section 10ASection 142(1)Section 143(2)Section 147Section 40

195(1) of the Act which attracted the provisions of section 40(a)(ia) of the Act; and (ii) and though the assessee company had during the subject year carried out international transactions with its Associated Enterprises (AEs) of Rs.23,97,35,320/-, but the AO in the course of the original assessment proceedings had failed to make a reference

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

ITA 1191/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16
For Appellant: \nShri M.V. Prasad, CAFor Respondent: \nMs. U. Mini Chandran
Section 143(3)Section 147Section 148Section 250

195 (Bom). The Hon'ble High Court, by drawing support from the\nlandmark judgment of the “Full bench” of the Hon'ble High Court of\nDelhi in the case of CIT Vs. Kelvinator of India (2002) 256 ITR 1 (Del)\n[which thereafter had been approved by the Hon'ble Apex Court in CIT\nVs. Kelvinator of India

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

ITA 1187/HYD/2018[2014-15]Status: DisposedITAT Hyderabad28 Apr 2023AY 2014-15

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 :

For Appellant: Shri Sriram Seshadri, CAFor Respondent: Shri Rajendra Kumar,CIT-DR
Section 115JSection 142(1)Section 143(2)Section 14ASection 14A(3)Section 47Section 56Section 56(2)(viia)Section 56(2)(viiia)

195 (SC) 6. PCIT Vs. Delhi International Airport Pvt. Ltd (2022) 143 taxmann.com 209. 7. PCIT Vs. Bombay Stock Exchange Ltd (2021) 129 taxmann.com 87 (SC). 8. Per contra, the ld.AR had submitted that in the Profit and Loss account, the assessee had only debited a total sum of Rs.68,26,342/- as expenses and out of the said amount

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes on the above terms

ITA 156/HYD/2023[2008-09]Status: DisposedITAT Hyderabad05 Feb 2024AY 2008-09

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

For Respondent: Ms. T. Vijaya Lakhsmi, CIT-DR
Section 143(3)Section 37(1)Section 40Section 40A(3)Section 40a

reassessment or re-computation, as envisaged in Section 132B(1)(i) of the Act. The Appellant in this regard three orders passed by Hon’ble ITAT Benches viz., (i) ACIT Vs. Narendra N. Thacker [(2016) 45 ITR Trib 188 (Kol)]; (ii) unreported judgement in ACIT Vs. Sajjan Singh and (iii) unreported order in Arun Bansal, Delhi Vs. ACIT, Delhi

CHANDINI DUVVURI,HYDERABAD vs. ITO (INT TAXN)-1, HYDERABAD

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

ITA 1432/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Dec 2025AY 2015-16

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

Section 147Section 148Section 148ASection 151A

195. Since the assessee had not filed the return of income under Section 139(1), the sources for the said deposits and interest receipts were not explained before the Department. Consequently, the A.O., after following due procedure prescribed under Section 148A, issued notice under Section 148 of the Act on 04.04.2022, with the prior approval of the competent authority. During

ANANTHA PVC PIPES PRIVATE LIMITED,ANANTAPUR vs. ACIT., CIRCLE-1, KURNOOL

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 317/HYD/2025[2017-18]Status: DisposedITAT Hyderabad06 Aug 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.317/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) M/S. Anantha Pvc Pipes Pvt. Ltd., Asst. Commissioner Of Income Tax, Vs. Circle-1, Kurnool. Anantapur. Pan:Aagca0936J (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri T. Rajendra Prasad, C.A. & Shri P. Rosi Reddy, Advocate. रधजस् व द्वधरध/Revenue By:: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 31/07/2025 घोर्णध की तधरीख/Pronouncement: 06/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Anantha Pvc Pipes Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 25.07.2024 For The A.Y. 2017-18. 2. At The Outset, It Is Observed That There Is A Delay Of 147 Days In Filing The Present Appeal Before The Tribunal. In This Regard, The

For Appellant: Shri T. Rajendra Prasad, C.AFor Respondent: : Dr. Sachin Kumar, SR-DR

reassessment proceedings and appellate proceedings before the Ld. CIT(A), it had earlier furnished all relevant documents during scrutiny proceedings under section 143(3) of the Act, such as, Audited financial statements, Cash book, Sales invoices, excise records and Bank statements, which are placed at page nos. 10 to 87 and 195 to 300 of the paper book

GUPTA ASHOK KUMAR,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(2), HYDERABAD

In the result, appeal of the assessee allowed

ITA 376/HYD/2024[2014-15]Status: DisposedITAT Hyderabad25 Jul 2025AY 2014-15

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, P Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 148Section 68

1.T. Act such as identity, creditworthiness of the lender and genuineness of the loan transaction are all not conclusively established by the assessee beyond doubt. The unsecured loan transaction between the assesse and the three entities i.e. Neelgagan, Nirmalkunj and 10 ITA.No.376/Hyd./2024 Nightbird to the extent of Rs.3,00,00,096/- is considered to be a bogus

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-3(4), HYDERABAD vs. ZARA INVESTMENTS PRIVATE LIMITED , SECUNDERABAD

In the result appeal filed by the Revenue is dismissed

ITA 64/HYD/2021[2011-12]Status: DisposedITAT Hyderabad18 Feb 2025AY 2011-12
For Appellant: Shri P.Murali Mohan Rao,ARFor Respondent: Shri Srinath Sadanala, DR
Section 132Section 133(6)Section 153A

section 68 of the Act. Once the\ninitial onus is discharged by the assessee, then the onus shifts\nto the Assessing Officer to prove otherwise. In the present case,\nalthough the assessee has filed relevant evidences and proved\nall three ingredients provided u/s 68 of the Act, but the\nAssessing Officer made addition as unexplained cash credit\nonly

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-3(4), HYDERABAD vs. ZARA INVESTMENTS PRIVATE LIMITED , HYDERABAD

In the result appeal filed by the Revenue is dismissed

ITA 65/HYD/2021[2016-17]Status: DisposedITAT Hyderabad18 Feb 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.64/Hyd/2021 & 65/Hyd/2021 (निर्धारण वर्ा/Assessment Year: 2011-12 & 2016-17) Asst.Commissioner Of Vs. M/S Zara Investments Income Tax Pvt.Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 18/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: These Appeals Filed By The Revenue Are Directed Against Order Dated 04.09.2020 Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”]-11, Hyderabad Pertaining To A.Y.2011-12 & 2016-17. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, The Appeals Filed By The Revenue Are Being Heard Together & Are Being Disposed Off, By This Common Order. Zara Investments Pvt. Ltd.

For Appellant: Shri P.Murali Mohan Rao,ARFor Respondent: Shri Srinath Sadanala, DR
Section 132Section 143(1)Section 153A

section 68 of the Act. Once the initial onus is discharged by the assessee, then the onus shifts to the Assessing Officer to prove otherwise. In the present case, although the assessee has filed relevant evidences and proved all three ingredients provided u/s 68 of the Act, but the Assessing Officer made addition as unexplained cash credit only