KINETA GLOBAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, 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, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

250(6) of the Act. 6. The appellant craves leave to add, alter or amend the above grounds of appeal before or in course of hearing.” 2. Succinctly stated, the AO based on information shared by the Director General of GST Intelligence, Hyderabad Zonal Unit, Hyderabad that the assessee company had irregularly availed Input Tax Credit (ITC) to the tune

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

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

250 of the Act dt. 20/06/2025 for the AY 2018-19 is erroneous both on facts and in law to the extent the order is prejudicial to the interests of the appellant. 2.The Ld. CIT (A) erred in dismissing the appeal without considering the submissions made by the assessee, which is against to the principles of natural justice and against

THULASI CHAMARTHY,CHITTOOR vs. INCOME TAX OFFICER, WARD - 1, CHITTOOR

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

250 of the Ld. Commissioner of Income Tax (Appeals) in not correct either on facts or in law and in both. 2. The Ld. Commissioner (Appeals) erred, in mechanically treating the entire property sold in May 2017 as one short-term capital asset being the residential flat constructed in March 2016, ignoring the clear distinction between the undivided share

RASHID HUSSAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(3), HYDERABAD

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

250 dated 15-07-2025 erroneous both on facts and in law to the extent the order is prejudice to the interests of the appellant. 2. The Ld. CIT(A) ought to have appreciated that the AO erred in not issuing the notice under section 143(2) of the LT Act, 1961. 3. The Ld. CIT(A) erred in considering

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:

250 of the Act for the AY 2013- 14 is erroneous and bad in law. 2. On the facts and in the circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the act of the learned A.O. who passed the order u/s 147 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:

250 of the Act for the AY 2013- 14 is erroneous and bad in law. 2. On the facts and in the circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the act of the learned A.O. who passed the order u/s 147 of the Act for the AY 2013-14 which is erroneous

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLOR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO ,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION) , NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

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)

u/s 143(3) of the Act and now it was reopened beyond the four yeas from the Assessment Year. In such a case, we are unable to find in the reasons recorded that there is no allegation on the part of the assessee in disclosing fully and truly all the material facts for completion of assessment. It is well settled

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

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

250 of the Act dt. 20/06/2025 for the AY 2019-20 is erroneous both on facts and in law to the extent the order is prejudicial to the interests of the appellant. 2. The Ld. CIT (A) erred in dismissing the appeal without considering the facts and circumstances of the case. 3. The Ld. CIT (A) ought to have considered

EYEGEAR OPTICS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 8(1), HYDERABAD

In the result, both the captioned appeals are allowed for statistical purposes in terms of our aforesaid observations

Bench: Us:

u/s 147 r.w.s 144 of the Income Tax Act, 1961 (for short “Act”) dated 16.12.2019 and 09.12.2019 for the A.Y.2012-13 and A.Y. 2013-14 respectively. As common issues are involved in all these appeals, therefore, the same are taken up and disposed of vide this consolidated order. 2. We shall first take up the appeal filed by the assessee company

RATNA INFRASTRUCTURE PROJECTS PRIVATE LIMITED,HYDERABAD vs. ITO, WARD-3(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2012-13 Ratna Infrastructure Projects Vs. The Income Tax Officer, Ward –3(3), Private Limited, Hyderabad. Hyderabad. Pan : Aadcr5836P. (Assessee) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 20.01.2025 Date Of Pronouncement: 12.02.2025

reassessment proceedings amounting to Rs.273,02,94,670/-. 5. The learned Commissioner ought to have appreciated that notice u/s 148 is issued on account of a letter from ADIT Kolkata, in respect of a transaction amounting to Rs.5,64,94,670/- and further in respect of transaction of Rs.267,38,00,000/-on merely a TEP. As there

DILEEP KUMAR SAKAMURI CHENCHU VENKATA,SRIKALAHASTI vs. INCOME-TAX OFFICER, WARD-1(3), TIRUPATI

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Us:

250 of the Act is bad in law and in facts and circumstances of the case: 2. That on the facts and circumstances of the case and in law, the Ld. AO has erred in carrying out and the NFAC/CIT(A) have erred in confirming an addition on account of unexplained money amounting to INR 2,07,67,400 under

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

250 of the Act dt. 30/06/2025 for the AY 2014-15 is erroneous both on facts and in law to the extent the order is prejudicial to the interests of the appellant. 2. The Ld. CIT (A) erred in dismissing the appeal without considering the facts and circumstances of the case as also the settled position

JVR RETAILS PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE -2(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2012-13 Jvr Retails Private Limited Vs Dcit, Circle-2(1) C/O. Murali & Co. . Hyderabad Chartered Accountants 6-3-655/2/3, Somajiguda Hyderabad-500 082 Pan : Aaccv9428J (Appellant) (Respondent) Assessee By: Shri M.V.Joshi Appeared For P.Murali Mohan Rao, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.01.2023 Date Of Pronouncement: 31.01.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.03.2021 Passed U/S. 263 By The Learned Principal Commissioner Of Income Tax -2, Hyderabad Relating To A Y 2012-13. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Domestic Company Engaged In The Business Of Retails & Manufacturing Of Jewelry. It Filed Its Return Of Income Declaring Total Income Of Rs. 49,97,390/- On 08.09.2012 Which Was Processed U/S 143(1) On 21.02.2013. Subsequently, The Ao Reopened The Assessment By Recording Reasons As Per Provisions Of Section 147. The Reasons To Believe Which Was Put Up Before The Ld.Pcit-2 For Approval & Which Has Been Reproduced By The Ao In The Body Of The Assessment Order Read As Under:-

250 shares was available. 5. The Ld.Pr.CIT ought to have appreciated the fact that the AO has reopened the assessment u/s. 147 of the Act with prior approval of Pr.CIT and passed order under 143(2) r.w.s 147, wherein only part of the allotment of shares was disallowed after examining the balance sheet and investment, and now a different stand