ANKIT JAIN,HYDERABAD. vs. ACIT., CENTRAL CIRCLE - 1(2), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, Ankit Jain vs. ACIT/DCIT to the extent provided in section 144B

ANKIT JAIN, HYDERABAD. vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD.

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, Ankit Jain vs. ACIT/DCIT to the extent provided in section 144B

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)

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference

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:-

reassessment proceedings u/s. 143(3) r.w.s. 147 and has not meddled with the above issue as he was fully satisfied with the details furnished as available with him. So, the Ld.Pr.CIT cannot direct the Ld.AO us/. 263 of the Act to re-examine the same issue or conduct further enquiries on the issue already considered

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

Bench: Us:

2. The order passed by the Learned Principal Commissioner of Income Tax (PCIT) under Section 263 is in violation of the principles of natural justice as the appellant was not provided with a sufficient and proper opportunity to present their case. The appellant was deprived of the opportunity to substantiate the facts and provide relevant documentary evidence, which makes

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

2,51,11,160/- from Salary & Other Sources. The original assessment u/s 143(3) was completed on 04.03.2005. Later, the case was reopened under section 147 of the Act and a reassessment order u/s 143(3) r.w.s. 147 was passed on 21.07.2010. On review, the CIT(C) found that key issues, including diversion of funds and the opening balance

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

2,51,11,160/- from Salary & Other Sources. The original assessment u/s 143(3) was completed on 04.03.2005. Later, the case was reopened under section 147 of the Act and a reassessment order u/s 143(3) r.w.s. 147 was passed on 21.07.2010. On review, the CIT(C) found that key issues, including diversion of funds and the opening balance

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,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,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

PRYSMIAN CAVI E SISTEMI S.R.L,HYDERABAD vs. DCIT (INT,TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

u/s. 263 dated 13.03.2006, the Ld. AO passed order\nunder section 143(3) read with section 263 of the Act on 29.03.2006, wherein\nhe estimated 5% profit on the offshore contract receipts of Rs.9,68,78,721/-\nresulting in an addition of Rs.48,43,936/-.\n4. Aggrieved, the assessee also filed an appeal before the Ld. CIT(A)\nchallenging

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 of orders prejudicial to revenue. (1)The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

2), Guntur [2011] 16\ntaxmann.com 24 (Visakhapatnam); M/s. KNR Constructions\nLtd., Hyderabad ITA.No.946/Hyd./2015; decision of ITAT,\nAgra Bench, Agra in the case of PNC Construction Co. Ltd.,\nvs. DCIT [2013] 44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench,\nAgra in the case of CIT vs. PNC Construction

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

In the result appeals filed by the Revenue\nITA

2), Guntur [2011] 16\ntaxmann.com 24 (Visakhapatnam); M/s. KNR Constructions\nLtd., Hyderabad ITA.No.946/Hyd./2015; decision of ITAT,\nAgra Bench, Agra in the case of PNC Construction Co. Ltd.,\nvs. DCIT [2013] 44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench,\nAgra in the case of CIT vs. PNC Construction

DY.COMMISSIONER OF INCOME TAX, CIRCLE 2(2), HYDERBAD vs. SEW INFRASTUCTURE LIMITED, HYDERABAD

2), Guntur [2011] 16\ntaxmann.com 24 (Visakhapatnam); M/s. KNR Constructions\nLtd., Hyderabad ITA.No.946/Hyd./2015; decision of ITAT,\n\nAgra Bench, Agra in the case of PNC Construction Co. Ltd.,\nvs. DCIT [2013] 44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench,\nAgra in the case of CIT vs. PNC Construction

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

2), Guntur [2011] 16\ntaxmann.com 24 (Visakhapatnam); M/s. KNR Constructions\nLtd., Hyderabad ITA.No.946/Hyd./2015; decision of ITAT,\n20\nITA. Nos.1721, 1722 & 1723/Hyd./2017\nAnd ITA.No.1416/Hyd./2019\nAgra Bench, Agra in the case of PNC Construction Co. Ltd.,\nvs. DCIT [2013] 44 ITD 577 (Agra-Tribu.) and on the\nRevenue's appeal against the Order of ITAT, Agra Bench