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

Bench: Us:

reassessment order, if passed, would result in a baseless and unwarranted demand, causing undue hardship to the appellant.” 3 Sri Edupayala Vana Durga Bhavani 3. Succinctly stated, the assessee, an AOP, had not filed its return of income for the subject year, i.e., A.Y. 2016-17. The A.O., based on information that the assessee had during the subject year made

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. ABIR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal of the revenue is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Asst. Commissioner Of Vs. Abir Infrastructure Pvt. Income-Tax, Ltd., Hyderabad. Central Circle – 1(3), Hyderabad. Pan – Aafc3608N (Appellant) (Respondent)

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 of the proceedings under this section, or recomputed the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned(hereinafter in this section and in sections

INDRANI PRASAD ,NEW DELHI vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, HYDERABAD

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

u/s 143(3) of the Income Tax Act, 1961, in short, the Act. Heard both the parties. Case files perused. 2. We first of all advert to the Revenue’s cross appeal ITA No.467/Hyd/2020 challenging correctness of CIT (A)’s action quashing the impugned assessment for want of a valid section 143(2) notice vide following lower appellate discussion

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. INDRANI PRASAD , NEW DELHI

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

u/s 143(3) of the Income Tax Act, 1961, in short, the Act. Heard both the parties. Case files perused. 2. We first of all advert to the Revenue’s cross appeal ITA No.467/Hyd/2020 challenging correctness of CIT (A)’s action quashing the impugned assessment for want of a valid section 143(2) notice vide following lower appellate discussion

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED ,HYDERABAD vs. INCOME TAX OFFICERS ,WARD -1(2), HYDERABAD

In the result, appeal of the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2012-13 Country Club Hospitality & Vs. Income-Tax Officer, Ward Holidays Ltd., Hyderabad. – 1(2), Hyderabad. Pan – Aaacc 8276 B (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Rohit Mujumdar Date Of Hearing: 08/02/2022 Date Of Pronouncement: 17/02/2022

u/s 143(3) rws 147 may be quashed. 7.1 The ld. AR also submitted that the AO made reopening of the assessment beyond 4 years. For this, he relied on the following cases: 1. MSEB Holding Co. Ltd., [2020] 113 taxmann.com 163(SC) 2. GB Bros. & Konda Rajagopala Chetty Beedi Factory (P) Ltd., [2003] 132 Taxman

DR.REDDY'S LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, we hold that the Tax Authorities were not justified in apportioning R & D expenditure and ESOP cost to the units which claimed exemption u/s 10B, 80IB and 80IC of the Act

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

reassessment beyond 4 years is barred by limitation and the allocation of R&D expenses to special units is a mere change of opinion. Hence, the proceedings u/s 148 of the Act are void ab initio and deserves to be quashed. 1.4 In this regard, we rely on various case laws as referred to in the case law compendium. Without

DR.REDDY'S LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, we hold that the Tax Authorities were not justified in apportioning R & D expenditure and ESOP cost to the units which claimed exemption u/s 10B, 80IB and 80IC of the Act

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

reassessment beyond 4 years is barred by limitation and the allocation of R&D expenses to special units is a mere change of opinion. Hence, the proceedings u/s 148 of the Act are void ab initio and deserves to be quashed. 1.4 In this regard, we rely on various case laws as referred to in the case law compendium. Without

DR.REDDY'S LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

In the result, we hold that the Tax Authorities were not justified in apportioning R & D expenditure and ESOP cost to the units which claimed exemption u/s 10B, 80IB and 80IC of the Act

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

reassessment beyond 4 years is barred by limitation and the allocation of R&D expenses to special units is a mere change of opinion. Hence, the proceedings u/s 148 of the Act are void ab initio and deserves to be quashed. 1.4 In this regard, we rely on various case laws as referred to in the case law compendium. Without

ARKAY ENERGY (RAMESWARM) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed\nin such case vide DIN ITBA/AST/F/148A/2022-23/1051563421(1) dated 29/03/2023 and\nannexed herewith for reference,\n2. I, therefore, propose to assess or reassess such income or recompute the loss or the\ndepreciation allowance or any other allowance or deduction for the Assessment Year

PARIGE VENKAT RAM REDDY,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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

GARUDAPALLY SHRUTHI GUPTA,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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

TRICITIES SECURITY AND ALLIED SERVICES PRIVATE LIMITED,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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

BALLELA SAI SREE ,NELLORE 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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

GARUDAPALLY SHRUTHI GUPTA,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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

SANJAY GARUDAPALLY,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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

KAUSHIK REDDY PADI ,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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

BALLELA SAI SREE,NELLORE 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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26

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.

u/s 132 at my office M/s. KMR Estates and Builders Pvt. Ltd., No. 1175, Road No.56, Jubilee Hills, Hyderabad. However, we have submitted detailed reconciliation statement after verification of our bank accounts and books of account of the company in respect of sale consideration received through channel. As per the said reconciliation statement we have received an amount of Rs.78.26