INDRANI PRASAD ,NEW DELHI vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, HYDERABAD

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

249 (Delhi) and the recent decision in Shri Jai Shiva Shankar Traders (P.) Ltd. (supra) hold likewise. 23. With the legal position being abundantly clear that a reassessment order cannot be passed without compliance with the mandatory requirement of notice being issued by the AO to the Assessee under Section

DEEPTI SOCIAL SERVICE SOCIETY,HINDUPUR vs. ITO., EXEMPTION WARD, TIRUPATI,

Bench: Us:

reassessment notice under Section 148, whereas such notice is required to be issued only through the Faceless regime in accordance with Section 151A r.w.s.144B. The initiation of proceedings by the Jurisdictional Assessing Officer, being contrary to the prescribed faceless procedure, is void ab initio and liable to be quashed.” As the assessee society by raising the aforesaid additional ground

SHAIK ABDUL AZIZ,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-1, KARIMNAGAR

Appeal are allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

reassessment Under Section 148 is served on 18.8.2014. Orders might have been passed on or before 31.12.2015 as per Section 153(2). The orders are passed on 30.3.2016 beyond time limit specified in Section 153(2). The orders passed are barred by limitation specified in Section 153(2) and liable to be quashed”. 3. Before us, Ld.AR heavily stressed

SULTANA RAFAT, ,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-1, KARIMNAGAR, KARIMNAGAR

Appeal are allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

reassessment Under Section 148 is served on 18.8.2014. Orders might have been passed on or before 31.12.2015 as per Section 153(2). The orders are passed on 30.3.2016 beyond time limit specified in Section 153(2). The orders passed are barred by limitation specified in Section 153(2) and liable to be quashed”. 3. Before us, Ld.AR heavily stressed

SHAIK ABDUL AZIZ,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-1, KARIMNAGAR

Appeal are allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

reassessment Under Section 148 is served on 18.8.2014. Orders might have been passed on or before 31.12.2015 as per Section 153(2). The orders are passed on 30.3.2016 beyond time limit specified in Section 153(2). The orders passed are barred by limitation specified in Section 153(2) and liable to be quashed”. 3. Before us, Ld.AR heavily stressed

BATTA ESHWARAMMA,R.R.DIST vs. INCOME TAX OFFICER, WARD-8(1), , HYDERABAD

In the result, all the appeals of the assessees are allowed and appeal of revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

249 (Amritsar Bench) 3. CIT Vs. Srinival Rao Hoskote, ITA Nos. 1154 & 1155/Bang/2015, dated 21/02/2018 4. Manish Maheshwar Vs. ACIT, 289 ITR 322 5. Ramballab Gupta Vs. ACIT, 288 ITR 347 6. Ld. DR relied on the orders of revenue authorities and relied on the order of Gudwill Housing Ltd. Vs. ITO, [2014] 45 Taxmann.com 144. 7. Considered the rival

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

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

249 (MP) (cited supra), after considering the above judgment of the Hon'ble Supreme Court has held that the expenditure incurred by the assessee therein in connection with the execution of a mortgage deed to secure a loan was revenue expenditure as there was no regulation regarding the application of capital subsidy to any specific purpose. 6. In the case

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

In the result, appeal of the Assessee is\nallowed

249(3) of Act\nand ought to have contended the delay in filing the appeal and\nadjudicated the grounds on merit.\n4. The Ld. CIT(A) ought to have admitted and heard the appeal on the\nbasis of merits, rather than dismissing the appeal without\nappreciating that the delay is due to reasons that are beyond the\ncontrol

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 :

249,590/- and addition of Rs.5,14,80,879/- under section 56(2)(viia) of the Act, the ld.CIT(A) had held at pages 58 to 65 as under : The facts of the case are that 11 companies amalgamated with the appellant vide the order of High Court dated 10.10.2013 w.e.f 01.04.2011. The amalgamating companies had identical shareholders and shareholding

RAMKY INFRASTRUCTURE LIMITED, HYDERABAD,HYDERABAD vs. JCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2009-10 Ramky Infrastructure Ltd, Vs. Joint Commissioner Of Hyderabad. Income Tax, Pan:Aaacr8627B Circle 3(1), Hyderabad. (Appellant) (Respondent) Assessee By: Shri A.V. Raghuram. Revenue By: Shri Jeevan Lal Lavidiya, Dr Date Of Hearing: 15/11/2022 Date Of Pronouncement: 28/11/2022 O R D E R Per Laliet Kumar, J.M

249. It is submitted that the AO also disallowed claim to an extent of Rs.4,74,2747. 7. It is submitted that the assessment passed on 11.11.2011 under section 143(3) of the Act by the AO got merged with the subsequent reassessment

LAXMI DHARAMSOTH,MANCHYA THANDA vs. ITO., WARD-1, WARANGAL

Bench: Us:

reassessment stating that the AO had reasons to believe that the income has escaped assessment. But on what reasons the learned AD has opted to re-open the assessment and the copy of the approval taken is not provided to the Appellant. 3. The Appellant has been under medical care since 2013 for the Chronic Kidney related alignments

VANASOWRABHA ASSOCIATES,WARANGAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, WARANGAL

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

Bench: Shri Laliet Kumar & Shri Manjunatha G

reassessment proceedings. Since, for assessment year 2014-15, i.e., the year under consideration, the learned CIT(A) had merely relied on the order of the predecessor for assessment year 2009-10, which stood subsequently quashed by this Tribunal, the assessee deserves to get relief on merits also for the year under consideration. ITA No.439/Hyd/2023 10 7. As stated earlier

VENU GOPAL KARAVADI, HYDERABAD,HYDERABAD vs. ITO, WARD-4(2), HYDERABAD, HYDERABAD

In the result appeal filed by Assessee is allowed

Bench: Shri B. Ramakotaiahassessment Year: 2009-10 Shri Venu Gopal Karavadi, Vs. Ito, Hyderabad. Ward – 4(2), Hyderabad. Pan- Bdbpk1736J (Appellant) (Respondent) Assessee By : Shri K.A Sai Prasad Shri B. Suresh Babu Revenue By : Date Of Hearing : 25-04-2018 Date Of Pronouncement : 27-04-2018 Order Per Shri B. Ramakotaiah, Am: This Is An Appeal By Assessee Against The Order Of Ld. Cit(A)-1, Hyderabad Dated 06.10.2016. Apart From The Issues Originally Contested In Appeal I.E Addition U/S Sec. 68 Of The It Act Of Two Deposits Of Rs. 4.45 Lakhs & Rs. 7.5 Laksh In Two Banks, Assessee Also Raised The Additional Grounds That Initiation Of Proceedings U/S 147 Of The It Act Ceased To Survive As The Officer Has Not Made Any Additions On The Issue On Which The Reasons For Reopening Are Based, Hence, A.O Is Not Justified In Making The Addition On Other Issues. We Have Heard Ld. Counsel & Ld. Dr

249) Madras HC by placing reliance on the judgement of SC in the case of Rajesh Jhaveri (supra) held that the assessing officer was barred from initiating reassessment proceedings u/s 147 when the time for issuance of notice u/s 143(2) had not expired. However, taken a different view in the case of ITO Vs. K M Pachiyappan

ALLRUI SRINIVAS RAJU,HYDERABAD vs. DCIT, CIRCLE-12(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1923/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2016-17) Allrui Srinivas Raju, Vs. Dcit, Hyderabad. Circle-12(1), Pan: Ahepr6968H Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri K C Devdas, Ca Assessee Represented By राज"वका""त"न"ध"व/ : Dr. Narendra Kumar Naik, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 12/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Allrui Srinivas Raju, (“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 17/10/2025 For The A.Y.2016-17. Allrui Srinivas Raju Vs. Dcit 2. The Assessee Has Raised The Following Rounds Of Appeal:

reassessment proceedings, the Ld. AO observed that the assessee had entered into a JDA dated 10.07.2015 with M/s Jeedimetla Residential Homes Private Limited along with three other land owners. According to the Ld. AO, the assessee was entitled to 20% share in the transaction arising out of the said JDA. The Ld. AO therefore computed an amount of Rs.12

COGNIZANCE CONSTRUCTIONS PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

In the result, appeal of the Assessee is allowed for\nstatistical purposes

reassessment.\n4. The Notice U/s 148 dated 30.03.2021 is issued by the\nIncome Tax Officer Ward 1(1) Hyderabad. However, the\nassessment is taken up and completed by\nAdditional/Joint/Deputy/Assistant Commissioner of Income\nTax/Income-tax Officer, National Faceless Assessment\nCentre, which is against the laid legal principle that that\nassessment cannot be completed under borrowed\nsatisfaction.\n5. Ld.AO/NFAC erred in issue

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KURNOOL vs. PANYAM CEMENTS & MINERAL INDUSTRIES LIMITED, NANDYAL

In the result, both the appeals by the Revenue are partly allowed and the C

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

249/-, Short Term Capital Gains of Rs.3,48,886/- and Long Term Capital Gains of Rs.20,71,49,940/-. Finally, the assessee admitted net business loss of Rs.12,44,29,420/. The return was processed u/s.143(1) of the Income Tax Act, 1961 [Act]. Subsequently, the Assessing Officer re-opened the assessment u/s.147 of the Act on the ground that

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KURNOOL vs. PANYAM CEMENT & MINERAL INDUSTRIS LIMITED , NANDYAL

In the result, both the appeals by the Revenue are partly allowed and the C

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

249/-, Short Term Capital Gains of Rs.3,48,886/- and Long Term Capital Gains of Rs.20,71,49,940/-. Finally, the assessee admitted net business loss of Rs.12,44,29,420/. The return was processed u/s.143(1) of the Income Tax Act, 1961 [Act]. Subsequently, the Assessing Officer re-opened the assessment u/s.147 of the Act on the ground that

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

section 132. He can always retract in such situation if he can show that the statement has been made on MIstaken belief of facts, he can retract from the statement if he can show that facts on the basis of which admission was made are incorrect”. In the case of the assessee, the circumstances explained by the assessee would clearly