KRISHNA MURTHY ELLA,HYDERABAD vs. DCIT-CIRCLE-1(2), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.585/Hyd/2023 & Sa No.10/Hyd/2024 (Arising Out Of Ita No.585/Hyd/2023) (िनधा"रण वष"/Assessment Year: 2014-15) Shri Krishna Murthy Ella Vs. Dy. C. I. T. Hyderabad Circle 1(2) Pan:Aacpe6389G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 18/07/2024 घोषणा की तारीख/Pronouncement: 14/08/2024 आदेश/Order

56(2)(vii)(c) of the Act, the law is very clear, where an assessee receives any property other than the immovable property for a consideration which is less than the aggregate fair market value of the property by an amount exceeding Rs.50,000, the aggregate fair market value of such property as exceeded such consideration should be treated

ACIT, CIRCLE-2(1), HYDERABAD vs. Y S JAGAN MOHAN REDDY, KADAPA

In the result, cross objection filed by the assessee is\nallowed

56(1)(vii) of the Act. The Ld.CIT(A), after\nconsidering the relevant facts has rightly deleted the additions\nmade by the Assessing Officer towards cost of acquisition of\nRs.95 crores on ‘protective basis' and substantive addition of\n44 crore in the hands of the assessee. Thus, we are inclined to\nuphold the findings of the Ld.CIT(A) and dismiss

SAMA SANGEETA REDDY REP. BY GPA HOLDER SAMA SUNIL KUMAR REDDY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(2), HYDERABAD.

In the result appeal of the assessee allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(vii)(b) of the Income Tax Act, 1961. 3. Aggrieved by the assessment order, the assessee preferred appeal before the learned CIT(A). Before the learned CIT(A), the assessee neither appeared nor furnished any details, even though, the case was listed for hearing on 6 occasions. Therefore, the learned CIT(A) disposed of the appeal filed

SYED AHMED ZEESHANUDDIN,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2 , HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

56(2)(vii) of the Act. The DRP, vide directions issued u/s 144C(5) of the Act on 26/12/2023, rejected the objections filed by the assessee and upheld the additions proposed by the Ld.AO. Thereafter, the Ld.AO passed final assessment order u/s 153C r.w.s.144C(13) of the Act, on 19/01/2024 and determined the total income at Rs.4

ASRA AHMED ,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

56(2)(vii) of the Act. The DRP, vide directions issued u/s 144C(5) of the Act on 26/12/2023, rejected the objections filed by the assessee and upheld the additions proposed by the Ld.AO. Thereafter, the Ld.AO passed final assessment order u/s 153C r.w.s.144C(13) of the Act, on 19/01/2024 and determined the total income at Rs.4

C5 INFRA PRIVATE LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.332/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) C5 Infra (P) Ltd Vs. Acit Secunderabad Central Circle 2(3) Pan:Aafcc2138K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca Shri C. Maheshwar Reddy, Ca राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2025 घोषणा की तारीख/Pronouncement: 25/07/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated 10/03/2023 Of The Learned Cit (A)-12, Hyderabad, For The A.Y.2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

56,77,225/-. Thereafter, a search & seizure action u/s 132 of the Act was carried out in the case of the assessee on 07/01/2021. During the course of search proceedings, some excel sheets named working.xlsx, jmmr25.11.2016.xlsx containing the names and amounts written against them were found from the email of one Shri B. Veeranjaneyulu, Sr. Accountant, of the assessee company

RAMULU MANTHRI,HYDERABAD vs. INCOME TAX OFFICER, WARD-15(1), HYDERABAD

In the result, appeal of the Assessee is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

reassessment proceedings under section 147 of the Act; 5. That the Ld. CIT(A) erred failed to apricate the fact that the issue of section 56(2)(vii

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

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

AMSRI INFRA PROJECTS PRIVATE LIMITED,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), HYDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

2(47)(v) of the IT Act which was the ground for initiation of action u/s.153C of the IT Act), ought to have dropped the proceedings initiated u/s.153C of the IT Act. 5. The Hon'ble CIT(A) ought not to have upheld the action of the assessing officer by sustaining the disallowance to the extent of 50% in respect

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE -1(2) , HYDERABAD vs. AMSRI BUILDERS PRIVATE LIMITED, SECUNDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

2(47)(v) of the IT Act which was the ground for initiation of action u/s.153C of the IT Act), ought to have dropped the proceedings initiated u/s.153C of the IT Act. 5. The Hon'ble CIT(A) ought not to have upheld the action of the assessing officer by sustaining the disallowance to the extent of 50% in respect

AMSRI BUILDERS PRIVATE LIMITED,SECUNDRABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

2(47)(v) of the IT Act which was the ground for initiation of action u/s.153C of the IT Act), ought to have dropped the proceedings initiated u/s.153C of the IT Act. 5. The Hon'ble CIT(A) ought not to have upheld the action of the assessing officer by sustaining the disallowance to the extent of 50% in respect

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE -1(2) , HYDERABAD vs. AMSRI INFRA PROJECTS PRIVATE LIMITED, SECUNDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

2(47)(v) of the IT Act which was the ground for initiation of action u/s.153C of the IT Act), ought to have dropped the proceedings initiated u/s.153C of the IT Act. 5. The Hon'ble CIT(A) ought not to have upheld the action of the assessing officer by sustaining the disallowance to the extent of 50% in respect

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

PULLALAREVU ANUSHA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

GAVIREDDYGARI HARIKISHORE REDDY,ANANTHAPUR vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

PULLALAREVU ANUSHA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous