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,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,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

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

253 has been noted to record that grant of approval means due application of mind on the subject matter approved which satisfies all the legal and procedural requirements. There is an exhaustive discussion on the requirement of prior approval under section 153D of the Act and it was noted that the requirement of approval cannot be treated as mere formality

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

ACIT., CIRCLE-16(2), HYDERABAD, HYDERABAD vs. M/S DECCAN CHRONICLE HOLDINGS LIMITED, HYDERABAD

In the result, appeal of the revenue is dismissed

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2007-08 Asst. Commissioner Of Income- Vs. Deccan Chronicle Holdings Tax, Circle – 16(2), Hyderabad. Ltd., Hyderabad.

reassessment proceedings u/s 147 of the Act as not sustainable and the consequent disallowances being treated as infructuous, the disallowances made by the AO are adjudicated on merits. 5. Aggrieved by the order of CIT(A), the revenue is in appeal before us raising the following grounds of appeal: I. The order of the CIT(A) is erroneous

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

253/-, and interest on delayed receivables of Rs. 32,93,986/-. 9 M/s. Callidus Cloud (India) Private Limited 6. Aggrieved by the final assessment order, the assessee is now in appeal before us. 7. The learned counsel for the assessee, Shri Alisagar Rampurawala, C.A., referring to the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C

DCIT, CIRCLE-14(1), HYD, HYDERABAD vs. M.R.V. PRASAD, HYD, HYDERABAD

Appeal is dismissed and assessee’s cross objection

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

3) r.w.s. 147 dated 30.12.2010, the Assessing Officer again reopened the assessment for the same reasons recorded earlier and proceeded with the reassessment. On the objections raised by the appellant on the reopened reassessment proceedings, the Assessing Officer brought out that since the merits of the case were not decided by the appellate authorities and the initial reassessment was annulled

DY.CIT, CIRCLE-1(2),, HYDERABAD vs. M/S CONCORD DRUGS LTD.,, HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

253 3. Sargam Cinema Vs. CIT, 197 Taxman 203 (SC) 4. CIT Vs. Freedom Board & Paper Mills, 57 Taxmann.com 383 (P&H) b) He submitted that DVO report per se is not an information for initiating reopening of assessment proceedings. He brought to our notice the reasons for reopening u/s 148, which is placed on record. The main reason

CONCORD DRUGS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

253 3. Sargam Cinema Vs. CIT, 197 Taxman 203 (SC) 4. CIT Vs. Freedom Board & Paper Mills, 57 Taxmann.com 383 (P&H) b) He submitted that DVO report per se is not an information for initiating reopening of assessment proceedings. He brought to our notice the reasons for reopening u/s 148, which is placed on record. The main reason

DY.CIT, CIRCLE-1(2),, HYDERABAD vs. M/S CONCORD DRUGS LTD.,, HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

253 3. Sargam Cinema Vs. CIT, 197 Taxman 203 (SC) 4. CIT Vs. Freedom Board & Paper Mills, 57 Taxmann.com 383 (P&H) b) He submitted that DVO report per se is not an information for initiating reopening of assessment proceedings. He brought to our notice the reasons for reopening u/s 148, which is placed on record. The main reason

DY.CIT, CIRCLE-1(2),, HYDERABAD vs. M/S CONCORD DRUGS LTD.,, HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

253 3. Sargam Cinema Vs. CIT, 197 Taxman 203 (SC) 4. CIT Vs. Freedom Board & Paper Mills, 57 Taxmann.com 383 (P&H) b) He submitted that DVO report per se is not an information for initiating reopening of assessment proceedings. He brought to our notice the reasons for reopening u/s 148, which is placed on record. The main reason

RAJKUMAR JINDAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

147] (SC), wherein it was held that – the service of the notice prescribed by Section 34 of the Indian Income-tax Act, 1922, for the purpose of commencing proceedings for reassessment is not a mere procedural requirement: it is a condition precedent to the initiation of proceedings for assessment under section 34 of the Act. (iii) The decision

PAYAL JINDAL ,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(2), HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

147] (SC), wherein it was held that – the service of the notice prescribed by Section 34 of the Indian Income-tax Act, 1922, for the purpose of commencing proceedings for reassessment is not a mere procedural requirement: it is a condition precedent to the initiation of proceedings for assessment under section 34 of the Act. (iii) The decision

SHIV KUMAR MITTAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(2), HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamonyassessment Year: 2009-10 Shiv Kumar Mittal, Vs. Income-Tax Officer, Hyderabad. Ward – 8(2), Hyderabad. Pan – Acipm 3813 D Appellant Respondent Assessee By: Shri Vikash Modi Revenue By: Smt. V. Aparna Date Of Hearing: 04/06/2019 Date Of Pronouncement: 30/08/2019 O R D E R Per Smt. P. Madhavi Devi, J.M. This Is An Appeal Of The Assessee For The Ay 2009-10 Against The Order Of Cit(A) – 8, Hyderabad, Dated, 16/02/2018. 2. Brief Facts Of The Case Are That The Assessee, An Individual, Had Sold A Property Situated At Kondapur Grampanchayat, Serilingampally Mandal, Rr District Vide Sale Deed No. 4100/2008 Dated 5Th June, 2008 For A Consideration Of Rs. 15,48,000/-, Whereas The Guideline Value Of The Property As Adopted By The Stamp Valuation Authority Was Rs. 50,56,000/-. Since The Assessee Did Not Offer Any Capital Gains On This Transaction To Tax, Ao Initiated Proceedings U/S 147 Of The Act By Issuing A Notice U/S 148 On 24/03/2016, Which Was Served On The Assessee By Way Of Affixture At The Last Known Address & Thereafter Notice U/S 142(1) Was Also Issued On 09/05/2016. Since There Was No Reply From The Assessee, A 2 I.T.A. No. 633/Hyd/18 Shiv Kumar Mittal, Hyd..

u/s 147 of the Act. Similar issue had arisen before us, in the case of Rajkumar Jindal in ITA No. 56 & 57/Hyd/2019 and vide order dated , it was held as under: “3. Ld. Counsel for the assessee, while reiterating the submissions made before the authorities below, submitted that the assessees’ filed their returns of income for the AY.2010-11