NATURAL POWER ASIA PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-16(1), HYDERABAD

Bench: Us:

reassessment, then, if the said claim is found to be 9 Natural Power Asia Pvt. Ltd. in order, the CIT(A) in the exercise of the powers vested with him under sub-section (1) of Section 251

EYEGEAR OPTICS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 8(1), HYDERABAD

In the result, both the captioned appeals are allowed for statistical purposes in terms of our aforesaid observations

Bench: Us:

reassessment proceedings beyond the time-limit prescribed under the first proviso to section 147 of the Act. 13. Admittedly, the legislature in all its wisdom had vide the Finance (No.2) Act 2024 w.e.f. 01.10.2024 inserted the “Proviso” to section 251

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

reassessment under section 147, it was clear that the later makes a fresh assessment of the entire income of the respondent/ assessee and hence, the Hon'ble High Court was right in proceeding on the basis that the earlier assessment order had been effaced by the subsequent order. Thus, it is submitted that the ratio laid down in Sun Engineering

ACIT CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

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

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

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

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

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

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

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

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

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

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

MADHUCON PROJECTS LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

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

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

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

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

TOURS5 COM,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

Bench: Us:

reassessment, then, if the said claim is found to be in order, the CIT(A) in the exercise of the TOURS5 COM, HYDERABAD. powers vested with him under sub-section (1) of Section 251

TOURS5 COM,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

Bench: Us:

reassessment, then, if the said claim is found to be in order, the CIT(A) in the exercise of the TOURS5 COM, HYDERABAD. powers vested with him under sub-section (1) of Section 251

EYEGEAR OPTICS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CRICLE-8(1), HYDERABAD

In the result, both the captioned appeals are allowed for\nstatistical purposes in terms of our aforesaid observations

reassessment proceedings beyond the\ntime-limit prescribed under the first proviso to section 147\nof the Act.\n13. Admittedly, the legislature in all its wisdom had vide the\nFinance (No.2) Act 2024 w.e.f. 01.10.2024 inserted the “Proviso\"\nto section 251

SURENDER KUMAR BHOJWANI,HYDERABAD vs. ITO, INTL. TAXTION -1, HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

251 (Mad). 10. Per contra, the Ld. Departmental Representative (for short, “DR”) relied on the orders of the authorities below. The Ld. DR submitted that as the assessee had not raised the claim for deduction in his return of income, therefore, he cannot in the course of the present proceedings under section 147 of the Act, which

VENUGOPAL REDDY GELIVI,HYDERABAD vs. ITO (INT TAXN)-1, HYDERABAD

sections": [ "147", "144", "148", "50C", "251" ], "issues": "Whether the initiation of reassessment proceedings under Section 147 was based on valid

KAUSALYA AGRO FARMS AMD DEVELOPERS PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes, in terms of our above findings

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

reassessment proceedings, the assessee filed its reply on 12.01.2022, enclosing copies of the books of account, computation of total income, and list of bank accounts. However, the Ld. AO was not satisfied with the explanation offered by the assessee and, accordingly, issued a show-cause ITA No.804/Hyd/2025 5 notice along with a draft assessment order, proposing a disallowance under section

INCOME TAX OFFICER, WARD-1, ADONI vs. T RAMA SUBBA REDDY , ADONI

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

251 are, indeed, very wide; but, wide as they are, they do not go to the extent of displacing powers under, say, sections 147, 148, and 263 of the Act." 6.9 The law is well settled that issues not considered in assessment, cannot be taken up in appeal. As is evident from the original assessment order the A.0 had accepted

THE PRUDENTIAL CO-OPERATIVE URBAN BANK LIMITED,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment has been opened were not dealt in the previous occasion. Therefore we do not find any merits in the argument of the Ld. AR. Accordingly, we dismiss the appeal of the assessee on this ground. 8. Now coming to the other grounds of the assessee with regard to the action of the Ld. CIT(A) in remanding the matter

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

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

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

251 of the Act brought in by the Finance Act, 2024, w.e.f. 7 Chandini Duvvuri 01.10.2024, empowering the CIT(A) to set aside assessments passed under Section 144 of the Income-tax Act, 1961. Considering the fact that the reassessment