MAHUA BHARATPUR EXPRESSWAYS LIMITED, ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

274 of the Act. All of the above grounds of appeal are without prejudice and notwithstanding each other. The appellant craves leave to add, alter, omit or substitute any or all of the above grounds of appeal, at any time before or at the time of hearing”. Page 3 of 38 ITA TP Nos 67 and 493 of 2022 Western

WESTERN UP TOLLWAY LIMITED,NEW DELHI vs. DCIT CIRCLE -8(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

274 of the Act. All of the above grounds of appeal are without prejudice and notwithstanding each other. The appellant craves leave to add, alter, omit or substitute any or all of the above grounds of appeal, at any time before or at the time of hearing”. Page 3 of 38 ITA TP Nos 67 and 493 of 2022 Western

NTT DATA BUSINESS SOLUTIOS PRIVATE LIMITED ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

274 read with 270A of the Act. 7 ITA.No.489/Hyd./2022 The Appellant craves leave to add to, alter, omit or substitute any or all of the above grounds of appeal or produce further documents at any time before or during the appeal proceedings.” 3. The assessee has also raised additional ground in the instant appeal under Rule

DSM SHARED SERVICES INDIA PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 8(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1358/Hyd/2024 Assessment Year 2021-2022 Dsm Shared Services India Private Limited, The Dcit, Circle-8(1), Hyderabad – 500 081. Hyderabad – 500 081. Vs. Telangana. Telangana. Pan Aadcd8407C (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09.12.2025 घोषणा की तारीख/Pronouncement: 12.12.2025 आदेश/Order

274 of the Act, for non-maintenance of information on "receivables" in Form 3CEB. 12. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in imposing penalty under section 271AA of the Act, without appreciating that there was a reasonable cause of failure to furnish information and/or documents as required

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

274 r.w.s. Section 270A is bad in law.” 3. The brief facts of the case are that the assessee, CallidusCloud India Private Limited, is engaged in the business of providing sales support, marketing and consulting services and software development to its group companies. The assessee filed its return of income for A.Y. 2021–22 on 19.02.2022, declaring total income

HARI KRISHNA LEELA PRASAD PALADUGU,HYDERABAD vs. INCOME TAX OFFICER, WARD - 6(1), HYDERABAD

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

274 r.w.s. 271D of the Act, was issued on 26.08.2019 and called upon the assessee to explain as to why penalty shall not be levied for contraventions of provisions of section 269SS of the Income Tax Act, 1961 for accepting sale consideration of Rs.15,78,000/- in cash. In response, the assessee, vide letter dated 12.09.2019, submitted that, the assessee

MOOLA PADMAJA,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(2), HYDERABAD

In the result, the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2012-13 Moola Padmaja Vs. Acit,Cc-3(2) 8-1-293/A/74/A 7Th Floor Dwaraka Nagar Colony Aaykar Bhawan Narayanamma Engineering Basheer Bagh College, Raidurg Hyderabad-500 004 Hyderabad-500 008 Pan : Aoipp2482B Assessment Year: 2012-13 Vinod Aerakula Vs Acit,Cc-3(2) B-109, Western Plaza 7Th Floor Hussain Shahwali Darha Aaykar Bhawan Shaikpet, Hyderabad Basheer Bagh Telangana Hyderabad-500 004 Pan : Aoopa5855R (Appellant) (Respondent) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri K.P.R.R.Murthy, Sr.Ar Date Of Hearing: 15.02.2023 Date Of Pronouncement: 22.02.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): The Above Two Appeals Filed By The Respective Assessees Are Directed Against The Separate Orders Dated 31.03.2022 & 27.3.2022 Respectively Of The Learned Cit(A) (Appeals)-11, Hyderabad Relating To Ay 2012-13. Since Identical Grounds Have Been Raised By The Respective Assessees, Therefore, These Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience.

274 of the Act should specifically state the grounds mentioned in Section 271(1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. q) Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which

VINOD AERUKALA ,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(2), HYDERABAD

In the result, the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2012-13 Moola Padmaja Vs. Acit,Cc-3(2) 8-1-293/A/74/A 7Th Floor Dwaraka Nagar Colony Aaykar Bhawan Narayanamma Engineering Basheer Bagh College, Raidurg Hyderabad-500 004 Hyderabad-500 008 Pan : Aoipp2482B Assessment Year: 2012-13 Vinod Aerakula Vs Acit,Cc-3(2) B-109, Western Plaza 7Th Floor Hussain Shahwali Darha Aaykar Bhawan Shaikpet, Hyderabad Basheer Bagh Telangana Hyderabad-500 004 Pan : Aoopa5855R (Appellant) (Respondent) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri K.P.R.R.Murthy, Sr.Ar Date Of Hearing: 15.02.2023 Date Of Pronouncement: 22.02.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): The Above Two Appeals Filed By The Respective Assessees Are Directed Against The Separate Orders Dated 31.03.2022 & 27.3.2022 Respectively Of The Learned Cit(A) (Appeals)-11, Hyderabad Relating To Ay 2012-13. Since Identical Grounds Have Been Raised By The Respective Assessees, Therefore, These Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience.

274 of the Act should specifically state the grounds mentioned in Section 271(1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. q) Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which

PRATIMA REDDY MUTHU,HYDERABAD vs. ACIT., CIRCLE-14(1), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1310/Hyd/2025 Assessment Year 2010-2011 Pratima Reddy Muthu, Hyderabad – 500 034. The Acit, Circle-14(1), Vs. Hyderabad – 500 004. Telangana. Pan Aaopm8335J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Yogesh K Jagia & Sri Amit Sood, Advocates. राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 24.11.2025 घोषणा की तारीख/Pronouncement: 24.12.2025 आदेश/Order

reassessment proceeding in absence of requisite approval as mandated under section 151 of Act vitiate the entire assessment proceedings. 14) That impugned order passed is contrary to and not in adherence with Faceless Appeal Scheme 2021, as amended from time to time. 15) That all the grounds of appeals are without prejudice to each other. 16) That appellant craves leave

SUBBALAKSHMAMMA PINNAMA,THUMMALAGUNTA,TIRUPATI vs. INCOME TAX OFFICER, WARD-1(1), TIRUPATI

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

Bench: the Ld. CIT(A).

274 r.w.s. 270A. During the penalty proceedings, the assessee submitted explanations and stated that, the delay in filing the return was due to disputes with the developer, uncertainty regarding her share of property, applicability of Section 45(5A), and other personal circumstances. The A.O. did not 3 Subbalakshmi Pinnama accept these explanations and held that, the assessee admitted the income

GADDAM MOHAN REDDY,NIZAMABAD vs. INCOME TAX OFFICER, WARD 1, NIZAMABAD, NIZAMABAD

Bench: the AO during re-assessment proceedings.4. The authorities below further failed to appreciate that on the same set of facts, the AO with all his expertise on the provisions of the Act has allowed the deduction claimed Under Section 54F of the Act in the assessment order passed Under Section 143(3) r.w.s Section 147 of the Act and that deduction claimed by the appellant Under Section 54F of the Act was by inadvertent.

reassessment order, dated 11/12/2017. 5. The PCIT based on the aforesaid facts set aside the order passed by the AO under section 143(3) r.w.s 147 of the Act, dated 11/12/2017 to the file of the Faceless Assessing Officer (FAO), i.e., Assessment Unit (AU), with a direction to give effect to his order passed under section

SYED GULAM MOHIUDDIN,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-1, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita No.136/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Syed Gulam Vs. Income Tax Officer Mohiuddin (International Taxation)-1 Hyderabad Hyderabad Pan:Decpm0365H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Assessment Order Dated 12.01.2023 Of The Learned Assessing Officer (International Taxation-1), Hyderabad, Relating To A.Y.2017-18. 2. The Grounds Raised By The Assessee Read As Under: “1. The Final Assessment Order Passed By The Income Tax Officer (Int Taxn)-1,Hyd (Herein After Referred To As 'Ao) Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant.

274 rws 271AAC(1) of the Income Tax Act. 23. The assessee may, add or alter or amend or modify or substitute or delete and/or rescind all or any of the Grounds of objections at any time before or at the time of hearing of the objection.” Page 3 of 16 ITA No 136 of 2023 Syed Gulam Mohiuddin

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

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

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

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

274. 4. We have carefully considered the rival submissions and perused the material placed on record including the case laws relied upon. It is a settled legal position that while the expression “sufficient cause” appearing in section 253(5) of the Income Tax Act, 1961 (“the Act”) is to be construed liberally, such liberal approach cannot be extended to cases

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

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

274.\n4. We have carefully considered the rival submissions and perused the\nmaterial placed on record including the case laws relied upon. It is a settled\nlegal position that while the expression “sufficient cause” appearing in section\n253(5) of the Income Tax Act, 1961 (“the Act”) is to be construed liberally, such\nliberal approach cannot be extended to cases

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 :

274/- which included interest of Rs. 726/- from Fixed Deposit Receipts and profit on sale of fixed assets of Rs. 16,52,225/-. As against this, the respondent assessee had claimed administrative and miscellaneous expenditure written off amounting to Rs. 8.75 Crores. For the Assessment Year 2008-09, the assessee had filed return declaring loss of Rs. 6.60 Crores approximately

SHARATH KUMAR REDDY SAREDDY,WANAPARTHY, MAHABUB NAGAR. vs. INCOME TAX OFFICER, WARD -1, MAHABUBNAGAR

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1096/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Sharath Kumar Reddy Vs. Income Tax Officer Sareddy, Wanaparthy Ward – 1 Mahbubnagar Mahbubnagar Pan:Hpwps0712H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/07/2025 घोषणा की तारीख/Pronouncement: 20/08/2025 आदेश/Order

274(S.C) and submitted that when the amendment provides a specific date of its applicability, then the same cannot be treated as retrospective in nature. He has then relied upon the judgment of the Hon'ble Supreme Court in the case of CIT vs. Vatika Township (P) Ltd reported 367 ITR 466 (S.C) that the Hon'ble Supreme Court

KANAKA CHALAM VOLETY,CALIFORNIA vs. INCOME TAX OFFICER, WARD-12(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

reassessment proceedings u/s 147 of the Income Tax Act, 1961 had been carried out in the case of the assessee for the said assessment year. Therefore, the Assessing Officer initiated proceedings u/s 147 of the Act, and issued notice u/s 148 of the Act, on 24.03.2023 requesting the assessee to furnish his return of income within thirty days. However

DCIT, CIRCLE-17(1), HYD, HYDERABAD vs. ECI ENGINEERING & CONSTRUCTION CO. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

reassessment have been raised by the Assessee for the first time before the Hon ITAT and it was neither raised before the AO nor before the TA CIT (A). Therefore, the Additional Grounds of Appeals filed on 11.01.2017 are not admissible. Reliance is placed on the following decisions in this regard: > Brooke Bond India Ltd (1991) 59 Taxmann