BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

reassessment order u/s.147 r.w.s.144B of the Act dated 01.03.2024 and the notice of demand dated 01.03.2024 Issued u/s 158 of the Act are also bad in law and unsustainable and the same, is hereby, quashed and set aside. 4 On the facts and in the circumstances of the case and in law, the Assessment Unit/NaFAC erred by making the additions

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

reassess the assessment already made without following the procedure under Section 147 or Section 148 of the Act and determine the total income of the assessee. The arguments raised by the counsel for the assessee, in light of the provisions of Section 153A(1)(a) and Form ITR-6, that the moment the assessee files a return in response

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD vs. AMSRI BUILDERS , SECUNDERABAD

In the result, the appeal of the Revenue for A

Bench: Shri Manjunatha G. Hon’Ble & Shri K. Narasimha Chary Hon’Ble

41(1) of the Act. 17. Coming back to the additional grounds filed by the Revenue in light of provisions of Section 28(i) of the Act. The Revenue has raised additional grounds and challenged that the amount of advance received from Smith Group of Companies was appropriated by the assessee for the work done by it and other works

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD vs. AMSRI BUILDERS, SECUNDERABAD

In the result, the appeal of the Revenue for A

reassessment proceedings the assessee cannot claim\ndeduction which was neither claimed nor allowed in original assessment\nand it is not open to the assessee to seek a review of concluded items.\nSince the proceedings under section 153A of the Act are analogous to\nproceedings under section 147 of the Act to the extent that these\nproceedings are for the benefit

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

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

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

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

KINETA GLOBAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, 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, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

41,94,492/- 4. Aggrieved, the assessee company carried the matter in appeal before the CIT(A), but without success. As the assessee company 5 Kineta Global Limited vs. DCIT despite sufficient opportunities had failed to participate in the appellate proceedings on either of the four dates on which the appeal was fixed for hearing before the CIT(A), therefore

INCOME TAX OFFICER, WARD-1, NELLORE vs. VENKATA RAMANAMMA SAKAMURI, NELLORE

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

Bench: Us:

41,125/-. 4. Aggrieved, the assessee carried the matter in appeal before the CIT(A). It was, inter alia, the claim of the assessee before the CIT(A) that as the AO had reopened his case vide notice issued under section 148 of the Act, dated 07/04/2022 i.e., beyond the period of three years from the end of the relevant

PRYSMIAN CAVI E SISTEMI S.R.L,HYDERABAD vs. DCIT (INT,TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

reassessment order dated 20.12.2006 under\nsection 143(3) r.w.s. 147 of the Act was adjudicated separately by the Tribunal\nvide order dated 30.11.2015. In that order, the Tribunal directed the Assessing\nOfficer to delete the addition made in respect of offshore contract receipts;\nestimate the income at 10% of the onshore contract works / services receipts;\nand specifically directed

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

section 147 which are for the benefit of the revenue and not an assessee, an assessee cannot be permitted to convert the reassessment proceedings as his appeal or revision, in disguise, and seek relief in respect of items earlier rejected or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to 'escaped income

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case