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

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

2. Legal Ground – Timelines under Section 153 of the Act 2.1. On the facts and in the circumstances of the case and in law, the Final Assessment Order dated 23.10.2024 passed by the Assessment Unit under Section 143(3) r.w.s. Section 144C(13) r.w.s. Section 144B of the Act is barred by limitation and therefore is void-ab-initio

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

SRIMAD VIRAT POTTULURI VEERA BRAHMENDRA SWAMULA VARI MATTAM,CUDDAPAH vs. ITO., EXEMPTION WARD, TIRUPATHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1164/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer Brahmendra Swamula Vari Exemption Ward, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Appellant) (Respondent) आ.अपी.सं /Ita No.2287/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer, Brahmendra Swamula Vari Exemption Ward, Chittoor, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Ravindra Chenji, Advocate (Through Hybrid Mode) राज" व "वारा/Revenue By:: Ms. Payal Gupta, Sr.Ar सुनवाई क" तार"ख/Date Of Hearing: 09/02/2026 घोषणा क" तार"ख/Pronouncement: 13/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: The Captioned Appeals Are Filed By Srimad Virat Pottuluri Veera Brahmendra Swamula Vari Mattam (“The Assessee”), Feeling Aggrieved By The

253(5) of the Income Tax Act, 1961 (“the Act”) is to be construed liberally, such liberal approach cannot be extended to cases where the delay is the result of inaction, negligence, or lack of bona fides on the part of the litigant. In the present case, the explanation furnished by the assessee does not inspire confidence. The demise

SRIMAD VIRAT POTHULURI VEERABRAHMENDRA SWAMULAVARI MUTTAM,KADAPA vs. ITO, EXEMPTION WARD, TIRUPATI, TIRUPATI

In the result, the appeal of the assessee in ITA No

2) of the Act\nwas issued by the Learned Assessing Officer (“Ld.AO") to the assessee on\n06.07.2017. After considering the submissions made by the assessee, the Ld.\nAO completed the assessment under section 143(3) of the Act on 18.12.2018,\ndetermining the total income of the assessee at Rs.77,45,857/-. Against the said\nassessment, the Ld. AO initiated penalty

CENTENARY BAPTIST CHURCH,WARANGAL vs. INCOME TAX OFFICER- EXEMPTIONS 1(4), HYDERABAD

In the result, both the appeals of assessee are dismissed

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

2. (EF) Memorandum of appeal not (properly) signed / verified by the person authroised u/s 140 of the IT Act, 1961. 3. (EF) Uploaded memorandum of appeal is not matching with the data entered in the e-filing (MOA generated through e-filing should be digitally signed and uploaded.). 4. (EF) Relevant order of assessment / reassessment / penalty / other proceedings not uploaded

CENTENARY BAPTIST CHURCH,WARANGAL vs. INCOME TAX OFFICER (EXEMPTIONS) 1(4), HYDERABAD

In the result, both the appeals of assessee are dismissed

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

2. (EF) Memorandum of appeal not (properly) signed / verified by the person authroised u/s 140 of the IT Act, 1961. 3. (EF) Uploaded memorandum of appeal is not matching with the data entered in the e-filing (MOA generated through e-filing should be digitally signed and uploaded.). 4. (EF) Relevant order of assessment / reassessment / penalty / other proceedings not uploaded

SRUJITHA ANNAPAREDDY,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-12(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No.253/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Surjitha Annapareddy Vs. Income Tax Officer Secunderabad Ward 12(1) Pan:Bnwpa6703L Hydrabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Y Srikanth Reddy, Dr सुनवाई की तारीख/Date Of Hearing: 22/05/2024 घोषणा की तारीख/Pronouncement: 22/05/2024

2 of 10 ITA No 253 of 2024 Surjitha Annapareddy subsequently reopened on the basis of information available in inside Portal, as per which income chargeable to tax has been escaped assessment on account of under estimation of capital gain from sale of shares. Therefore, a notice u/s 148 of the Act dated 31.03.2021 was issued and served

DCIT., CIRCLE-2(1), HYDRABAD vs. KALPTARU INVESTMENTS PRIVATE LIMITED, HYDERABAD

In the result, appeal ITA

253 Taxman 141 [Rajasthan-HC];\niii.\nJudgment of Hon'ble Gujarat High Court in the case of\nAnkit Financial Services Ltd. vs. DCIT, Circle-1(1)(2)\n[2017] 78 taxmann.com 58 [Gujarat-HC];\niv.\nJudgment of Hon'ble Supreme Court in the case of\nSecurities and Exchange Board of India vs. Rakhi Trading\nPrivate Ltd., in Civil Appeal No.1969