PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO ,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION) , NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

5 ITO vs. Shiva Kumar Thota jurisdiction assumed by the AO for framing the assessment was not as per the mandate of law. The Ld. CIT-DR submitted that the assessee respondent has challenged the validity of the jurisdiction assumed by the AO for framing the assessment vide his order passed under Section based on a fresh ground

SHIV KUMAR MITTAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(2), HYDERABAD

In the result, the appeals of both the assessees are allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2009-10 Shiv Kumar Mittal, Vs. Income-Tax Officer, Hyderabad. Ward – 8(2), Hyderabad. Pan – Acipm 3813 D Appellant Respondent Assessee By: Shri Vikash Modi Revenue By: Smt. V. Aparna Date Of Hearing: 04/06/2019 Date Of Pronouncement: 30/08/2019 O R D E R Per Smt. P. Madhavi Devi, J.M. This Is An Appeal Of The Assessee For The Ay 2009-10 Against The Order Of Cit(A) – 8, Hyderabad, Dated, 16/02/2018. 2. Brief Facts Of The Case Are That The Assessee, An Individual, Had Sold A Property Situated At Kondapur Grampanchayat, Serilingampally Mandal, Rr District Vide Sale Deed No. 4100/2008 Dated 5Th June, 2008 For A Consideration Of Rs. 15,48,000/-, Whereas The Guideline Value Of The Property As Adopted By The Stamp Valuation Authority Was Rs. 50,56,000/-. Since The Assessee Did Not Offer Any Capital Gains On This Transaction To Tax, Ao Initiated Proceedings U/S 147 Of The Act By Issuing A Notice U/S 148 On 24/03/2016, Which Was Served On The Assessee By Way Of Affixture At The Last Known Address & Thereafter Notice U/S 142(1) Was Also Issued On 09/05/2016. Since There Was No Reply From The Assessee, A 2 I.T.A. No. 633/Hyd/18 Shiv Kumar Mittal, Hyd..

5. Ld. Counsel for the assessee submitted that the assessee has been filing his returns of income from 2007-08 onwards mentioning new address only i.e., Indian Airlines Colony, Begumpet, Hyderabad – 16 and has drawn our attention to the income-tax returns, the copies of which are filed before us in the form of a paper book, wherein the said

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

5) of the Act dated 11.09.2024, partly allowed the objections of the assessee. In pursuance of the directions of the Hon’ble DRP, the learned TPO passed a giving effect order and the A.O. thereafter passed the final assessment order under Section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act on 23.10.2024, determining the total income

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA. Private Limited vs. ACIT 12. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain (supra) wherein a detailed discussion

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA. Private Limited vs. ACIT 12. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain (supra) wherein a detailed discussion

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA. Private Limited vs. ACIT 12. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain (supra) wherein a detailed discussion

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA. Private Limited vs. ACIT 12. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain (supra) wherein a detailed discussion

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

DCIT, CIRCLE-14(1), HYD, HYDERABAD vs. M.R.V. PRASAD, HYD, HYDERABAD

Appeal is dismissed and assessee’s cross objection

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

reassessment proceedings have been quashed, it resulted into deletion of the entire additions. Therefore, there is no need to consider and decide the remaining grounds on the merits in the appeal because the same would be of academic interest only”. 4. The Revenue vehemently contended during the course of hearing that the Assessing Officer had rightly set into motion Section

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

reassessment / penalty / other proceedings not uploaded. 5. (EF) petition and / or affidavit for condoning the delay in filing appeal is not uploaded. 6. (EF) Grounds of appeal before CIT(A) not uploaded. 7. (EF) Statement of Facts before CIT(A) not uploaded. 8. Uploaded Form 36 is not matching with e-filing Acknowledgment. Upload the correct Form 36 matching with

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

reassessment / penalty / other proceedings not uploaded. 5. (EF) petition and / or affidavit for condoning the delay in filing appeal is not uploaded. 6. (EF) Grounds of appeal before CIT(A) not uploaded. 7. (EF) Statement of Facts before CIT(A) not uploaded. 8. Uploaded Form 36 is not matching with e-filing Acknowledgment. Upload the correct Form 36 matching with

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

5 of 10 ITA No 253 of 2024 Surjitha Annapareddy of shares. The assessee has disclosed Long-Term Capital Gain derived from sale of shares and claimed exemption u/s 10(38) of the I.T. Act, 1961. The assessee had also reported Long-Term Capital Gain derived from sale of shares in ITR filed for the impugned A.Y in Schedule

PAYAL JINDAL ,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

In the result, the appeals of both the assessees are allowed

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

5 -: ITA. Nos. 56 & 57/Hyd/2019 plead ignorance about the new address and hence the notice u/s.148 of the Act was not validly served on the assessees. In support of this contention, he placed reliance upon the following : (i) Judgment of the Hon'ble Supreme Court of India in the case of (i) Y. Narayana Chetty and another

RAJKUMAR JINDAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

In the result, the appeals of both the assessees are allowed

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

5 -: ITA. Nos. 56 & 57/Hyd/2019 plead ignorance about the new address and hence the notice u/s.148 of the Act was not validly served on the assessees. In support of this contention, he placed reliance upon the following : (i) Judgment of the Hon'ble Supreme Court of India in the case of (i) Y. Narayana Chetty and another

GAJANAN FINANCIAL SERVICES PRIVATE LIMITED, HYDERABAD,HYDERABAD vs. ACIT, CIRCLE-2(3), HYDERABAD, HYDERABAD

Bench: Shri S.S. Godara & Shri L. P. Sahu(Through Virtual Hearing)

reassessment framed on 16.12.2011 disallowing/adding the short term capital gains of Rs.16,70,179 as not eligible to be set off against long term capital loss of Rs.5,18,09,507 (supra) under section 70(3) of the Income Tax Act (in short 'the Act') and upheld in the lower appellate order. 5. Learned counsel’s only argument in view