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

section 148 to 153 assess or reassess such income for such A.Y. Before initiating proceedings u/s 147 for re-assessment of any income, escapement of income should be proved and such escapement is based on fresh tangible material come to the possession of the Assessing Officer. In other Page

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

56 alone, income, profits and gains must be computed in accordance with the method of accounting regularly employed by the assessee. In this case, we are concerned with Section 28. Therefore, Section 145(1) is attracted to the facts of the present case. Under the mercantile system of accounting, what is due is brought into credit before it is actually

PRATHIMA RESORTS & RESTAURANTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

section 56(2)(x) and on-money\npayments made in cash in respect of lands purchased at\nRangareddyguda during the previous year relevant to A.Y\n2020-21 by the said assessee's. The AO made the said\ndiscussion with reference to the seized material and sworn\nstatements u/sec.132(4) relevant to the said issues and he\narrived at the conclusion

SPARK VIDYUTH PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Rangareddyguda during the previous year relevant to A.Y 2020-21 by the said assessees. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues and he arrived at the conclusion that income

DAKSHAYANI HORTICULTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Kodangal during 14 ITA.Nos.1333, 1331 & 1328/Hyd./2024 previous relevant to assessment year 2017-2018 by the said assessee’s. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues

PRATHIMA EGGSEL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Rangareddyguda during the previous year relevant to A.Y 2020-21 by the said assessees. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues and he arrived at the conclusion that income

PRATHIMA RESORTS & RESTAURANTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Rangareddyguda during the previous year relevant to A.Y 2020-21 by the said assessees. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues and he arrived at the conclusion that income

PRATHIMA EGGSEL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Rangareddyguda during the previous year relevant to A.Y 2020-21 by the said assessees. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues and he arrived at the conclusion that income

PRAYAGA GREEN MEADOWS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Kodangal during 14 ITA.Nos.1333, 1331 & 1328/Hyd./2024 previous relevant to assessment year 2017-2018 by the said assessee’s. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues

MSN INSTITUTE OF MEDICAL SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Rangareddyguda during the previous year relevant to A.Y 2020-21 by the said assessees. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues and he arrived at the conclusion that income

ADRIJA FARMS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

56(2)(x) and on-money payments made in cash in respect of lands purchased at Kodangal during 14 ITA.Nos.1333, 1331 & 1328/Hyd./2024 previous relevant to assessment year 2017-2018 by the said assessee’s. The AO made the said discussion with reference to the seized material and sworn statements u/sec.132(4) relevant to the said issues

MSN INSTITUTE OF MEDICAL SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

section 56(2)(x) and on-money\npayments made in cash in respect of lands purchased at\nRangareddyguda during the previous year relevant to A.Y\n2020-21 by the said assessee's. The AO made the said\ndiscussion with reference to the seized material and sworn\nstatements u/sec.132(4) relevant to the said issues and he\narrived at the conclusion

SPARK VIDYUTH PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

56(2)(x) and on-money payments made\nin cash in respect of lands purchased at Rangareddyguda\nduring the previous year relevant to A.Y 2020-21 by the said\nassessees. The AO made the said discussion with reference\nto the seized material and sworn statements u/sec.132(4)\nrelevant to the said issues and he arrived at the conclusion\nthat income

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

SRUTHI RIEDL,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-2, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Sruthi Riedl, Income Tax Officer, Hyderabad Vs. (International [Pan No. Aggpp6953R] Taxation)-2, Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा /Assessee By: Shri H. Srinivasulu, Ar /Revenue By: Ms. T. Vijaya Lakshmi, Cit-Dr राजस्‍वजस्‍व द्वारा सुनवाई ई की तारीखीख/Date Of Hearing: 28/08/2023 घोषणा की तारीखीख/Pronouncement On: 08/11/2023

sections 50C, 50CA.and 50D.” 2. The brief facts of the case are that assessee being an NRI has filed the return of income for the A.Y. 2016 - 17 declaring an income of Rs.18,26,340/- towards income from house property and towards income from short term and long term capital gains and the case was processed. Thereafter, information was received

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

DESU ENTERPRISES,ONGOLE vs. ITO., WARD-1, ONGOLE

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

reassessment proceedings are governed by the substituted\nreassessment regime introduced by the Finance Act, 2021, with effect from\nthat date, as held by the hon'ble Telangana High Court at para no. 17 of the\norder. Under the said regime, compliance with the mandatory procedure\nprescribed under section 148A of the Act is a condition precedent for issuance

RAIN CEMENTS LIMITED, HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2008-09 M/S. Rain Cements Ltd Vs. Dy. Commissioner Of (Formerly Known As Rain Income Tax, Circle 3 (1) Cii Carbon (India) Ltd Hyderabad Hyderabad Pan:Aabcr8858F (Appellant) (Respondent) Assessee By: Advocate Prathishta Singh & Advocate Deepak Chopra Revenue By: Dr.Rajendra Kumar, Cit-Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 24.03.2017 Passed U/S 143(3) R.W.S. 144C(5) R.W.S. 260 Of The I.T. Act For The A.Y 2008-09. 2. This Appeal Was Earlier Decided By The Tribunal Vide Order Dated 18.10.2019. Subsequently Vide Ma No.15/Hyd/2020, Dated 23.3.2021, The Tribunal Recalled The Entire Order For Fresh Adjudication. Therefore, This Is A Recalled Matter.

X apply only when there is any income arising from the international transaction, 5. The Ld. DRP/TPO erred in not appreciating that the amendment to section 92B would not apply to the year under consideration as it was inserted on a later date. The amendment has to be interpreted as prospective in nature. 6. The Ld. DRP/TPO erred

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