DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

80-IB (10) of the Act would be hit by sub-section (5) of section 80A of the act. 6. We are conscious that in absence of the provision contained in section 80A (5) of the Act, the Petitioners could have maintained the claim of deduction even before the CIT for the first time in Revision Application, though no such

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

80-IB (10) of the Act would be hit by sub-section (5) of section 80A of the act. 6. We are conscious that in absence of the provision contained in section 80A (5) of the Act, the Petitioners could have maintained the claim of deduction even before the CIT for the first time in Revision Application, though no such

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

80-IB (10) of the Act would be hit by sub-section (5) of section 80A of the act. 6. We are conscious that in absence of the provision contained in section 80A (5) of the Act, the Petitioners could have maintained the claim of deduction even before the CIT for the first time in Revision Application, though no such

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

80-IB (10) of the Act would be hit by sub-section (5) of section 80A of the act. 6. We are conscious that in absence of the provision contained in section 80A (5) of the Act, the Petitioners could have maintained the claim of deduction even before the CIT for the first time in Revision Application, though no such

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

80-IB (10) of the Act would be hit by sub-section (5) of section 80A of the act. 6. We are conscious that in absence of the provision contained in section 80A (5) of the Act, the Petitioners could have maintained the claim of deduction even before the CIT for the first time in Revision Application, though no such

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

80-IA (4) "(4) This section applies to- (i) any enterprise carrying on the business [of (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining] any infrastructure facility which fulfils all the following conditions) namely:- (a) it is owned by a company registered in India or by a consortium of such companies [or by an authority

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

80-IA (4) "(4) This section applies to- (i) any enterprise carrying on the business [of (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining] any infrastructure facility which fulfils all the following conditions) namely:- (a) it is owned by a company registered in India or by a consortium of such companies [or by an authority

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

Section 148 - to issue a reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which

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

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

Section 148 - to issue a reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which

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

80-IA for the first time in the return filed in response to notice under section 153A. In this regard, he relied upon the decision of the Hon’ble Supreme Court in the case of V.D. M.Rm.M.Rm. Muthaiah Chettiar Vs. CIT reported in (1969) 74 ITR 183 (SC) and CIT Vs. P.K. Kochammu Amma Peroke reported

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), HYDERABAD vs. INDU PROJECTS LIMITED, HYDERABAD

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

80-IA which was made first time in the return filed u/s 153A without appreciating the fact that the provisions of section 153A could not operate to advantage of the assessee, who chose not to make a claim in the manner lawfully open to it u/s 139(1) or 139(5) of the Act. 5) Whether on the facts

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), HYDERABAD vs. INDU PROJECTS LIMITED, HYDERABAD

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

80-IA which was made first time in the return filed u/s 153A without appreciating the fact that the provisions of section 153A could not operate to advantage of the assessee, who chose not to make a claim in the manner lawfully open to it u/s 139(1) or 139(5) of the Act. 5) Whether on the facts

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), HYDERABAD vs. INDU PROJECTS LIMITED, HYDERABAD

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

80-IA which was made first time in the return filed u/s 153A without appreciating the fact that the provisions of section 153A could not operate to advantage of the assessee, who chose not to make a claim in the manner lawfully open to it u/s 139(1) or 139(5) of the Act. 5) Whether on the facts

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), HYDERABAD vs. INDU PROJECTS LIMITED, HYDERABAD

Appeals are dismissed therefore

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

80-IA which was made first time in the return filed u/s 153A without appreciating the fact that the provisions of section 153A could not operate to advantage of the assessee, who chose not to make a claim in the manner lawfully open to it u/s 139(1) or 139(5) of the Act. 5) Whether on the facts

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD vs. GKC PROJECTS LIMITED, HYDERABAD

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

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

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD vs. GKC PROJECTS LIMITED, HYDERABAD

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

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

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD vs. GKC PROJECTS LIMITED, HYDERABAD

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

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

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD vs. GKC PROJECTS LIMITED, HYDERABAD

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

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