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. DCIT., CIRCLE-1(1), HYDERABAD

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

200. Subsequently, the CIT assumed jurisdiction under section 263 of the I.T. Act and directed the A.O. (i) to bring to tax the gain on account of foreign exchange fluctuation of Rs.15,46,428 as income from other sources; (ii) to disallow gratuity of Rs.1,32,95,577; and (iii) to disallow expenditure amounting to Rs.2,69,26,757 relatable

VENU GOPAL KARAVADI, HYDERABAD,HYDERABAD vs. ITO, WARD-4(2), HYDERABAD, HYDERABAD

In the result appeal filed by Assessee is allowed

Bench: Shri B. Ramakotaiahassessment Year: 2009-10 Shri Venu Gopal Karavadi, Vs. Ito, Hyderabad. Ward – 4(2), Hyderabad. Pan- Bdbpk1736J (Appellant) (Respondent) Assessee By : Shri K.A Sai Prasad Shri B. Suresh Babu Revenue By : Date Of Hearing : 25-04-2018 Date Of Pronouncement : 27-04-2018 Order Per Shri B. Ramakotaiah, Am: This Is An Appeal By Assessee Against The Order Of Ld. Cit(A)-1, Hyderabad Dated 06.10.2016. Apart From The Issues Originally Contested In Appeal I.E Addition U/S Sec. 68 Of The It Act Of Two Deposits Of Rs. 4.45 Lakhs & Rs. 7.5 Laksh In Two Banks, Assessee Also Raised The Additional Grounds That Initiation Of Proceedings U/S 147 Of The It Act Ceased To Survive As The Officer Has Not Made Any Additions On The Issue On Which The Reasons For Reopening Are Based, Hence, A.O Is Not Justified In Making The Addition On Other Issues. We Have Heard Ld. Counsel & Ld. Dr

200/- has escaped long term capital gain tax as per provisions of Sec. 50C of the IT Act. In the course of assessment proceedings, Assessee submitted that he has purchased a house for Rs. 64,65,418/- before due date of filing the return u/s 139 of the IT Act and produced proof for purchase of new house, therefore

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

200-201 of APB, therefore, as per subsection(1) of section 151 of the Act (as was available on the statute during the year under consideration) no notice under section 148 of the Act could be issued by the AO unless the Joint Commissioner of Income Tax was satisfied on 10 BA Continuum India Private Limited vs. DCIT the reasons

RAGHU SATYANARYANA KOLLU,KODAD vs. ITO., WARD-1, SURYAPET

In the result, both the captioned appeals are allowed in terms of the aforesaid observations

Bench: Us:

reassessment proceedings for the AY 2013-14. 9. On the facts and in the circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the order passed by the learned AO, National Faceless Assessment Centre u/s 147 rws 144 & 1448 of the Act for the AY 2013-14 which is erroneous

RAGHU SATYANARYANA KOLLU,KODAD vs. ITO., WARD-1, SURYAPET

In the result, both the captioned appeals are allowed in terms of the aforesaid observations

Bench: Us:

reassessment proceedings for the AY 2013-14. 9. On the facts and in the circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the order passed by the learned AO, National Faceless Assessment Centre u/s 147 rws 144 & 1448 of the Act for the AY 2013-14 which is erroneous

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

3 ITO vs. Shiva Kumar Thota deposited an amount of Rs.1.93 crores during the year under consideration, i.e., post demonetization, which was not commensurate with his return of income, initiated proceedings under section 147 of the Act. Order under section 148A(d) of the Act, dated 29/07/2022 was passed by the AO. Thereafter, the AO issued notice under section

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment 8 I.T.A. No. 607/Hyd/16 and others Megha Engg. & Infrastructure Ltd. proceedings because the original assessments were concluded earlier for most of the years. The return in response to notice u/s 153A

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment 8 I.T.A. No. 607/Hyd/16 and others Megha Engg. & Infrastructure Ltd. proceedings because the original assessments were concluded earlier for most of the years. The return in response to notice u/s 153A

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment 8 I.T.A. No. 607/Hyd/16 and others Megha Engg. & Infrastructure Ltd. proceedings because the original assessments were concluded earlier for most of the years. The return in response to notice u/s 153A

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment 8 I.T.A. No. 607/Hyd/16 and others Megha Engg. & Infrastructure Ltd. proceedings because the original assessments were concluded earlier for most of the years. The return in response to notice u/s 153A

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LIMITED, HYD, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment 8 I.T.A. No. 607/Hyd/16 and others Megha Engg. & Infrastructure Ltd. proceedings because the original assessments were concluded earlier for most of the years. The return in response to notice u/s 153A

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURES LIMITED, HYD, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment 8 I.T.A. No. 607/Hyd/16 and others Megha Engg. & Infrastructure Ltd. proceedings because the original assessments were concluded earlier for most of the years. The return in response to notice u/s 153A

INCOME TAX OFFICER, WARD 3(1), HYDERABAD vs. STYPACK PRIVATE LIMITED , HYDERABAD

In the result, the appeal of the revenue is dismissed, while the cross-objection of the assessee company is allowed in terms of our aforesaid observations

Bench: Us:

3. Succinctly stated, the AO based on information gathered from the Insight Portal and the order dated 28.04.2022 passed u/s 148A(d) of the Act, that the name of the assessee company, viz., Stypack Pvt. Ltd. (PAN : AACCS8673G), had surfaced as one of the beneficiaries in the course of search and seizure proceedings conducted u/s

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

200 crore turnover filter: i. Mindtree Limited ii. Great Software Laboratory Private Limited iii. Nihilent Limited iv. LTIMindtree Limited (formerly Larsen & Toubro Infotech Limited) v. Wipro Ltd. vi. Tata Elxsi Limited vii. Infosys Limited viii. Cybage Software Private Limited 4 M/s. Callidus Cloud (India) Private Limited (d) Inclusion of functionally different companies: i. Nihilent Limited ii. LTIMindtree Limited iii. Wipro

INCOME TAX OFFICER, WARD-8(1), HYDERABAD vs. DAGUMATI SWATHI, HYDERABAD

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

200/-; and (ii) deposited cash in a Savings Bank account: Rs.1,31,99,724/- but had not filed her return of income for the year under consideration, initiated proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 13/05/2021 was issued by the ITO, Ward-8(1), Hyderabad. 3. As is discernible from the assessment

S HARINATH CHOWDARY ,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(1), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi

section 50C of the Act and it was also held that the finally determined capital gains cannot exceed the capital gains originally assessed in the assessment order. 2.1. In the meantime,, the AO reopened the assessment for the A.Y.2007-08 u/s 147 of the Act by observing that the development agreement was dated 24.7.2003 and some of the terms or Clauses

EXEL RUBBER PRIVATE LIMITED,K.V.RANGAREDDY vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: “The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

200% under section 35(2AB) of the Act on account of clinical trial expenses incurred stating that the same was not being approved by Department of Scientific Institute and Research (DSIR) in Form 3CL. 8.2. The Ld. AO/DRP has erred in not appreciating that the explanation 1 to Section 35(2AB) specifically includes clinical trial expenses within its ambit