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

Section 153A deals with the assessment or reassessment of ‘total income’, as against assessment or re- assessment of such income i.e., income :44

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

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,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

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

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

44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench,\nAgra in the case of CIT vs. PNC Construction Co. Ltd.,\n[2015] 55 taxmann.com 21 (Allahabad-HC) dismissed the\nappeal of the Revenue by holding that assessee would be\nentitled to deduction u/sec.80IA even if project was not\nawarded solely

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

In the result appeals filed by the Revenue\nITA

44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench,\nAgra in the case of CIT vs. PNC Construction Co. Ltd.,\n[2015] 55 taxmann.com 21 (Allahabad-HC) dismissed the\nappeal of the Revenue by holding that assessee would be\nentitled to deduction u/sec.80IA even if project was not\nawarded solely

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

44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench,\nAgra in the case of CIT vs. PNC Construction Co. Ltd.,\n[2015] 55 taxmann.com 21 (Allahabad-HC) dismissed the\nappeal of the Revenue by holding that assessee would be\nentitled to deduction u/sec.80IA even if project was not\nawarded solely

DY.COMMISSIONER OF INCOME TAX, CIRCLE 2(2), HYDERBAD vs. SEW INFRASTUCTURE LIMITED, HYDERABAD

44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench,\nAgra in the case of CIT vs. PNC Construction Co. Ltd.,\n[2015] 55 taxmann.com 21 (Allahabad-HC) dismissed the\nappeal of the Revenue by holding that assessee would be\nentitled to deduction u/sec.80IA even if project was not\nawarded solely

ANKIT JAIN, HYDERABAD. vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD.

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

44,800/- as his unexplained investment under section 69 of the Act. Accordingly, the AO vide his order under section 143(3) r.w.s 147 of the Act, dated 11/12/2024 determined the income of the assessee at Rs.20,24,470/-. 4. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success. 5. The assessee being aggrieved

ANKIT JAIN,HYDERABAD. vs. ACIT., CENTRAL CIRCLE - 1(2), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

44,800/- as his unexplained investment under section 69 of the Act. Accordingly, the AO vide his order under section 143(3) r.w.s 147 of the Act, dated 11/12/2024 determined the income of the assessee at Rs.20,24,470/-. 4. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success. 5. The assessee being aggrieved

PRYSMIAN CAVI E SISTEMI SRL INDIA PROJECT OFFICE (FORMERLY PIRELLI CAVI SISTEMI S P A INDIA PROJECT OFFICE),HYDERABAD vs. DCIT,( INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

reassessment, the Ld. AO rejected the books\nof accounts of the assessee under section 145(3) and estimated profit of\nRs.1,54,46,987/- at the rate of 10% on offshore contract receipts of\nRs.15,44

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, the Ld. AO rejected the books\nof accounts of the assessee under section 145(3) and estimated profit of\nRs.1,54,46,987/- at the rate of 10% on offshore contract receipts of\nRs.15,44

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

reassessment proceedings it is not open to an assessee to seek a review of the concluded item, unconnected with the escapement of income, for the purpose of computation of the escaped income. 44. The appeals, consequently, succeed and are allowed. The orders of the High Court are set aside and those of the Tribunal restored. Since the assessee

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

reassessment regime under section 147 of the Income-\ntax Act, 1961. This new regime was introduced through\nsignificant amendments to section 147 and section 148,\nalong with the insertion of Explanations 1 and 2, and the\nconcept of "information suggesting escapement of income"\nwas explicitly defined. From the reading of Explanation 2 to\nSection 147, it is evident that

INCOME TAX OFFICER, WARD-8(1), HYDERABAD vs. DAGUMATI SWATHI, HYDERABAD

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

44,200/-; and (ii) deposited cash in a Savings Bank account: Rs.1,31,99,724/- but had not filed her return of income for the year under consideration, initiated proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 13/05/2021 was issued by the ITO, Ward-8(1), Hyderabad. 3. As is discernible from

VIJAYAWADA TOLLWAY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal filed by the assessee is\nOrder pronounced in the Open Court on 6th February, 2026

reassessment order dated 05.12.2019\npassed by the Ld. AO under section 143(3) read with section 147\nof the Act, the relevant portion of which is to the following effect:\nLess Prepaid taxes: TDS : 1,08,30,957\nAdvance Tax: 5,00,00,000\nRefundable\nLess refund already issued vide 143(1) dt 28.03.2014\nTotal Demand\nAdd: Interest u/s 234D