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

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

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

reassessment for\na block of years which are mentioned in that provision,\nsame alone would not be sufficient to justify steps in that\ndirection being taken, unless incriminating material so\nfound is likely to have an impact on total income of a\nparticular assessment year forming part of six assessment\nyears immediately preceding assessment year pertaining to\nsearch year

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

reassessment for\na block of years which are mentioned in that provision,\nsame alone would not be sufficient to justify steps in that\ndirection being taken, unless incriminating material so\nfound is likely to have an impact on total income of a\nparticular assessment year forming part of six assessment\nyears immediately preceding assessment year pertaining to\nsearch year

SRI EDUPAYALA VANA DURGA BHAVANI,HYDERABAD vs. INCOME TAX OFFICER, WARD-1, SANGAREDDY

Bench: Us:

u/s 147 of the IT Act estimating the income @ 8% on gross receipts of Rs. 2.48 crores. 4. The PCIT's erred in issuing show cause notice dated 13/12/2023 findings that the original assessment order was erroneous and prejudicial to the interests of the Revenue are arbitrary, perverse, and based on mere conjectures and surmises. 5. The directions issued

HIMASAGAR KRISHNA MUTHAPPAGARI,TIRUPATI vs. ITO., WARD-2(3), TIRUPATI

Bench: Us.

reassessment vide his order passed u/s 147 r.w.s. 144B of the Act, dated 22-03-2022. 13. Before proceeding any further, we deem it fit to cull out the provisions of Section 263 of the Act, which reads as under: “263. Revision

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

reassessment for a block of years\nwhich are mentioned in that provision, same alone would\nnot be sufficient to justify steps in that direction being\ntaken, unless incriminating material so found is likely to\nhave an impact on total income of a particular assessment\nyear forming part of six assessment years immediately\npreceding assessment year pertaining to search year

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment order and directing an examination of the Rs. 397 crore ADS proceeds and the Rs. 1122.00 crore opening balance. A notice u/s 143(2) was issued on 30.03.2012 and served on 31.03.2012, requiring the assessee’s appearance on 09.04.2012. 21.1. In response, the assessee submitted his reply on 02.04.2012, stating that he had filed an appeal before

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU , HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment order and directing an examination of the Rs. 397 crore ADS proceeds and the Rs. 1122.00 crore opening balance. A notice u/s 143(2) was issued on 30.03.2012 and served on 31.03.2012, requiring the assessee’s appearance on 09.04.2012. 21.1. In response, the assessee submitted his reply on 02.04.2012, stating that he had filed an appeal before

INCOME TAX OFFICER, WARD-1, ADONI vs. T RAMA SUBBA REDDY , ADONI

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment held that the total consideration on sale of land was Rs.4,67,20,000/- and not Rs.21.75,000/- as adopted by him in the regular assessment and allowed cost of acquisition of Rs.21,54,067/- without allowing any other claims made by the assessee and passed assessment order on 31.03.2016 u/s 143(3) r.w.s. 263

SPR INFRASTRUCTURE INDIA LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-3(2), HYDERABAD, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu(Through Virtual Hearing)

263 of the Income Tax Act, 1961 ('the Act'). Heard both the parties. Case files perused. 2. It is noticed at the outset that this is the second round of proceedings between the parties before us qua the assessee's identical/sole substantive grievance seeking to reverse both the lower authorities identical action income from other sources addition on various facets

SURESH PRODUCTIONS,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result, the appeal filed by the Revenue as well as all the appeals and C

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyappeal In Ita No Appellant Respondent A.Y 1429/Hyd/2014 Acit Circle M/S. Suresh 2003-04 13(1) Hyderabad Productions Hyderabad Co 78/Hyd/2014 M/S. Suresh Acit Circle 13(1) 2003-04 (Ita Productions Hyderabad 1429/H/2014) Hyderabad 2102/Hyd/2018 -Do- Addl.Cit, Range 13(Old) 2010-11 Range-14 (Present) Hyderabad 2103/Hyd/2018 -Do- Dy.Cit, Circle 14(1) 2012-13 Hyderabad 2104/Hyd/2018 -Do- -Do- 2013-14 2105/Hyd/2018 -Do- -Do- 2014-15 Assessee By: Shri K.C. Devdas, Ca Revenue By: Shri Shakeer Ahmed, Dr

reassessment proceedings are not in accordance with law in view of the first proviso to section 147 of the I.T. Act 15. Referring to the copy of the order passed u/s 143(3) r.w.s. 147 in case of SMFD for the A.Y 2003-04, he submitted that the Assessing Officer had reproduced clause

ACIT, CIRCLE-13(1), HYDERABAD vs. M/S SURESH PRODUCTIONS, HYDERABAD

In the result, the appeal filed by the Revenue as well as all the appeals and C

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyappeal In Ita No Appellant Respondent A.Y 1429/Hyd/2014 Acit Circle M/S. Suresh 2003-04 13(1) Hyderabad Productions Hyderabad Co 78/Hyd/2014 M/S. Suresh Acit Circle 13(1) 2003-04 (Ita Productions Hyderabad 1429/H/2014) Hyderabad 2102/Hyd/2018 -Do- Addl.Cit, Range 13(Old) 2010-11 Range-14 (Present) Hyderabad 2103/Hyd/2018 -Do- Dy.Cit, Circle 14(1) 2012-13 Hyderabad 2104/Hyd/2018 -Do- -Do- 2013-14 2105/Hyd/2018 -Do- -Do- 2014-15 Assessee By: Shri K.C. Devdas, Ca Revenue By: Shri Shakeer Ahmed, Dr

reassessment proceedings are not in accordance with law in view of the first proviso to section 147 of the I.T. Act 15. Referring to the copy of the order passed u/s 143(3) r.w.s. 147 in case of SMFD for the A.Y 2003-04, he submitted that the Assessing Officer had reproduced clause

SURESH PRODUCTIONS,HYDERABAD vs. ADDL. COMMISSIONER OF INCOME TAX, RANGE-13(OLD), RANGE-14(PRESENT), HYDERABAD

In the result, the appeal filed by the Revenue as well as all the appeals and C

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyappeal In Ita No Appellant Respondent A.Y 1429/Hyd/2014 Acit Circle M/S. Suresh 2003-04 13(1) Hyderabad Productions Hyderabad Co 78/Hyd/2014 M/S. Suresh Acit Circle 13(1) 2003-04 (Ita Productions Hyderabad 1429/H/2014) Hyderabad 2102/Hyd/2018 -Do- Addl.Cit, Range 13(Old) 2010-11 Range-14 (Present) Hyderabad 2103/Hyd/2018 -Do- Dy.Cit, Circle 14(1) 2012-13 Hyderabad 2104/Hyd/2018 -Do- -Do- 2013-14 2105/Hyd/2018 -Do- -Do- 2014-15 Assessee By: Shri K.C. Devdas, Ca Revenue By: Shri Shakeer Ahmed, Dr

reassessment proceedings are not in accordance with law in view of the first proviso to section 147 of the I.T. Act 15. Referring to the copy of the order passed u/s 143(3) r.w.s. 147 in case of SMFD for the A.Y 2003-04, he submitted that the Assessing Officer had reproduced clause

SURESH PRODUCTIONS ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(1), HYDERABAD

In the result, the appeal filed by the Revenue as well as all the appeals and C

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyappeal In Ita No Appellant Respondent A.Y 1429/Hyd/2014 Acit Circle M/S. Suresh 2003-04 13(1) Hyderabad Productions Hyderabad Co 78/Hyd/2014 M/S. Suresh Acit Circle 13(1) 2003-04 (Ita Productions Hyderabad 1429/H/2014) Hyderabad 2102/Hyd/2018 -Do- Addl.Cit, Range 13(Old) 2010-11 Range-14 (Present) Hyderabad 2103/Hyd/2018 -Do- Dy.Cit, Circle 14(1) 2012-13 Hyderabad 2104/Hyd/2018 -Do- -Do- 2013-14 2105/Hyd/2018 -Do- -Do- 2014-15 Assessee By: Shri K.C. Devdas, Ca Revenue By: Shri Shakeer Ahmed, Dr

reassessment proceedings are not in accordance with law in view of the first proviso to section 147 of the I.T. Act 15. Referring to the copy of the order passed u/s 143(3) r.w.s. 147 in case of SMFD for the A.Y 2003-04, he submitted that the Assessing Officer had reproduced clause

SURESH PRODUCTIONS,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result, the appeal filed by the Revenue as well as all the appeals and C

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyappeal In Ita No Appellant Respondent A.Y 1429/Hyd/2014 Acit Circle M/S. Suresh 2003-04 13(1) Hyderabad Productions Hyderabad Co 78/Hyd/2014 M/S. Suresh Acit Circle 13(1) 2003-04 (Ita Productions Hyderabad 1429/H/2014) Hyderabad 2102/Hyd/2018 -Do- Addl.Cit, Range 13(Old) 2010-11 Range-14 (Present) Hyderabad 2103/Hyd/2018 -Do- Dy.Cit, Circle 14(1) 2012-13 Hyderabad 2104/Hyd/2018 -Do- -Do- 2013-14 2105/Hyd/2018 -Do- -Do- 2014-15 Assessee By: Shri K.C. Devdas, Ca Revenue By: Shri Shakeer Ahmed, Dr

reassessment proceedings are not in accordance with law in view of the first proviso to section 147 of the I.T. Act 15. Referring to the copy of the order passed u/s 143(3) r.w.s. 147 in case of SMFD for the A.Y 2003-04, he submitted that the Assessing Officer had reproduced clause

ROCKWELL COLLINS (INDIA) ENTERPRISES PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-3(2), HYDERABAD

Appeal is allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11

reassessment proceedings, the Aa has not examined the issues for which earlier notices u/s 148 were issued and assessment was reopened as mentioned in the forgoing paras. Various items, as mentioned above, have been allowed as deductions without proper verification by the Aa. Hence, it was proposed to treat the assessment order, passed by the Aa, as erroneous

GANGA VINAY BABU,HYDERABAD vs. SIBENDU MOHARANA COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION & TRANSFER PRICING), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: S/Shri A .Mohan Alankamony & Chandra Mohan Gargassessment Year : 2013-14 Ganga Vinay Babu, C/O. Ch. Vs. Ito, International Taxation, Parthasarathy & Co., 1-1- Nellore. 298/2/B/3, 1St Floor, Ashok Nagar, Hyderabad Pan/Gir No.Ayxpg 9593 M (Appellant) .. ( Respondent) Assessee By : Shri K.A.Sai Prasad, Ar Revenue By : Shri B.Balakrishna, (Dr) Date Of Hearing : 12/10/ 2021 Date Of Pronouncement : 06/01/2022 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Cit (It& Tp), Hyderabad Dated 26Th February, 2020 For The Assessment Year 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal:

147 of the Act on 31.12.2018 assessing taxable income at Rs.10,61,720/-. 6. The CIT (IT & TP), Hyderabad, issued notice u/s 263 dated 11.12.2019, seeking to revise the assessment order passed u/s 143(3)/147 P a g e 3 | 9 Assessment Year : 2013-14 of the Act. The CIT (IT & TP), Hyderabad was of the view

SANJAY KUMAR SANGHI ,HYDERABAD vs. INCOME TAX OFFICERS ,WARD-12(4), HYDERABAD

Bench: Shri Laxmi Prasad Sahu & Shri K. Narasimha Charyassessment Years: 2012-13 Sanjay Kumar Sanghi, Vs. Income-Tax Officer, Hyderabad. Ward – 12(4), Hyderabad. Pan – Afvps 5491R (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri T. Sunil Goutam Date Of Hearing: 16/03/2022 Date Of Pronouncement: 23/03/2022

revision of order by Pr. CIT is bad in law. 5. Your Appellant submits that the Assessing Officer has considered all the facts while completing the assessment under section 143(3) r.w.s 147 including the issue raised under 263, therefore the order is not erroneous or prejudicial to the interests of revenue. 6. I Your appellant submits that the assessing