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

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

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

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

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

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

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

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

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

business income eligible for deduction u/s 80IA of the Act. He further contended that when the assessee was found indulged in the activity of inflating the expenditure and siphoning of the fund through the sub- contractor/sister concern, then the benefit of section 80IA of the Act cannot be allowed to the assessee in respect of disallowances made by the Assessing

PITTI HOLDINGS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

Business Loss ii) Share Capital/Other Capital. The AO passed the assessment stating that "After considening the assessee's submissions and documents filed in response to the statutory notices, no addition on the above issue(s) is made." 5. The facts stated by the assessee are conveniently incomplete. The information as mentioned in para-1 above is not made available during

THALLA SRISAILAM GOUD,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 9(1), HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

u/s 148 of the old law having been issued on 01.04.2021, the entire assessment proceedings consequent to such notice are bad in law in the light of the decision of the Apex Court in the Ashish Agarwal (444 ITR 1). 3. The Ld. Commissioner of Income-tax (Appeals)/NFAC erred rejecting the legal grounds raised by the Appellant w.r.t. initiation

SHIVA RANJANI VEJJA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-12(2) , HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

reassessment notice upon him. In this case the AO at Noida based on the address issued notice u/s 148. The assessee filed his return of income belatedly and stated that he was regularly assessed with ITO Delhi and thus challenged the jurisdiction. The HC observed that as per section 120, the Act does not authoritatively confer exclusive jurisdiction to specific

THE PRUDENTIAL CO-OPERATIVE URBAN BANK LIMITED,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

business income/activity, the expenditure is not allowed to be set of against income computed under other heads.” 5.1 The Ld. AR further submitted that the case of the assessee had already been subject to assessment u/s. 147 of the Act and the assessment order for the same was passed u/s. 143(3) r.w.s. 147

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

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

u/s 148 of the old law having been issued on 01.04.2021, the\nentire assessment proceedings consequent to such notice are bad in law in the\nlight of the decision of the Apex Court in the Ashish Agarwal (444 ITR 1).\n3. The Ld. Commissioner of Income-tax (Appeals)/NFAC erred rejecting the legal\ngrounds raised by the Appellant w.r.t. initiation

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

147 or 263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring

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

147 or 263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring

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

In the result, the C.O. filed by the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course

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

reassess such income for such assessment\nyear. Further, Section 147 makes it very clear that in\norder to invoke provisions of Section 147 of the Act, there\nshould be income which has escaped assessment, and such\nescapement should be based on fresh tangible material\nwhich comes to the possession of the AO subsequent to the\ncompletion of the original assessment

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

business profits under Section 28(i) of the Act. Thus, we are inclined to uphold the findings of LD.CIT(A) and dismiss the appeal filed by the Revenue. 19. In the result, the appeal of Revenue for A.Y. 2010-11 is dismissed. ITA No.1898 of 2018 for A.Y. 2011-12 20. The grounds raised by the Revenue in ITA No.1898/Hyd/2024

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

reassess such income for such assessment\nyear. Further, Section 147 makes it very clear that in\norder to invoke provisions of Section 147 of the Act, there\nshould be income which has escaped assessment, and such\nescapement should be based on fresh tangible material\nwhich comes to the possession of the AO subsequent to the\ncompletion of the original assessment

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

In the result appeals filed by the Revenue\nITA

reassess such income for such assessment\nyear. Further, Section 147 makes it very clear that in\norder to invoke provisions of Section 147 of the Act, there\nshould be income which has escaped assessment, and such\nescapement should be based on fresh tangible material\nwhich comes to the possession of the AO subsequent to the\ncompletion of the original assessment

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

reassess such income for such assessment\nyear. Further, Section 147 makes it very clear that in\norder to invoke provisions of Section 147 of the Act, there\nshould be income which has escaped assessment, and such\nescapement should be based on fresh tangible material\nwhich comes to the possession of the AO subsequent to the\ncompletion of the original assessment