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

u/s 142(1) of the Act dt.28.07.2009 were issued to the assessee. During the reassessment proceedings, the assessee objected to the reopening of the assessment which the AO rejected by way of passing a reasoned order. After providing due opportunity to the assessee and 4 B. Ramalinga Raju considering the partial information furnished by the assessee on 20.07.2010, along with

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

u/s 142(1) of the Act dt.28.07.2009 were issued to the assessee. During the reassessment proceedings, the assessee objected to the reopening of the assessment which the AO rejected by way of passing a reasoned order. After providing due opportunity to the assessee and 4 B. Ramalinga Raju considering the partial information furnished by the assessee on 20.07.2010, along with

RAIN CEMENTS LIMITED, HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2008-09 M/S. Rain Cements Ltd Vs. Dy. Commissioner Of (Formerly Known As Rain Income Tax, Circle 3 (1) Cii Carbon (India) Ltd Hyderabad Hyderabad Pan:Aabcr8858F (Appellant) (Respondent) Assessee By: Advocate Prathishta Singh & Advocate Deepak Chopra Revenue By: Dr.Rajendra Kumar, Cit-Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 24.03.2017 Passed U/S 143(3) R.W.S. 144C(5) R.W.S. 260 Of The I.T. Act For The A.Y 2008-09. 2. This Appeal Was Earlier Decided By The Tribunal Vide Order Dated 18.10.2019. Subsequently Vide Ma No.15/Hyd/2020, Dated 23.3.2021, The Tribunal Recalled The Entire Order For Fresh Adjudication. Therefore, This Is A Recalled Matter.

147 proceedings was not separately disallowed. 1.6 Without prejudice to the above, even post reassessment proceedings, there is no additional tax liability and that Appellant is liable to pay tax under the provisions of Minimum Alternative Tax (no adjustment made to the book profits) and thus the question of income having escaped assessment does not arise. Corporate Tax Matters

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2022-23/1051563421(1) dated 29/03/2023 and annexed herewith for reference, 2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other allowance or deduction for the Assessment Year

KAPIL PROPERTY DEVELOPERS LIMITED ,HANUMAKONDA vs. DY COMMISSIONER OF INCOME TAX , HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee

KAPIL FOOD AND STRUCTURE PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee

KAPIL INFRA AVENUES PRIVATE LIMITED ,VIJAYAWADA vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee

PITTI HOLDINGS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

reassess any other income, which may have escaped assessment but which did not form the subject 36 ITA.No.450/Hyd./2025 mater of me notice u/s 148. This view was adopted in the judgment of the Punjab & Haryana High Court in Vipan Khanna (Supra) and in the judgment of the Kerala High Court in Travancore Cements Limited (Supra) This line

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1), HYDERABAD

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

147 of the Act, dated 26/03/2025, based on the Notice u/s 148 of the Act, dated 29/11/2023 issued by the ACIT, Central Circle 1(1), Hyderabad, i.e., the JAO, as on date is squarely covered by the Judgment of the Hon’ble High Court of Telangana in the case of Kings Pride Infra Projects (P) Ltd. Vs. Deputy Commissioner

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

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

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

147 of the Act, dated 26/03/2025, based on the Notice u/s 148 of the Act, dated 29/11/2023 issued by the ACIT, Central Circle 1(1), Hyderabad, i.e., the JAO, as on date is squarely covered by the Judgment of the Hon’ble High Court of Telangana in the case of Kings Pride Infra Projects (P) Ltd. Vs. Deputy Commissioner

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

u/s 143(3) r.w.s 147 of the IT Act for the A.Y 2010-11. Respectfully following the above decisions (cited supra), we hold that the assessee, which is following a uniform and consistence method of accounting, and has claimed the expenditure in accordance with the notification of the Min of Corporate Affairs and the A.O has allowed the same

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

36,23,718/- during the subject year from M/s. Sauve Corporation India Pvt. Ltd. Accordingly, the AO, based on the aforesaid facts, observed that it was proved beyond doubt that the alleged purchases which the assessee company had claimed to have made from M/s. Sauve Corporation India Pvt. Ltd, were bogus and, thus, the entire amount of bogus expenditure

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

36,03,522/- for the A.Ys.2013-2014 and 2015-\n2016, [ITA.Nos.1721 & 1723/Hyd./2017 in appeals filed by\nthe assessee before the Tribunal] respectively on the\nground that when return of income was not filed\nu/sec.139(1) of the Act it not only contravenes Sec.80IA(4)\nand, therefore, unless the assessee files its return of income\nu/sec.139

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

In the result appeals filed by the Revenue\nITA

36,03,522/- for the A.Ys.2013-2014 and 2015-\n2016, [ITA.Nos.1721 & 1723/Hyd./2017 in appeals filed by\nthe assessee before the Tribunal] respectively on the\nground that when return of income was not filed\nu/sec.139(1) of the Act it not only contravenes Sec.80IA(4)\nand, therefore, unless the assessee files its return of income\nu/sec.139

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

36,03,522/- for the A.Ys.2013-2014 and 2015-\n2016, [ITA.Nos.1721 & 1723/Hyd./2017 in appeals filed by\nthe assessee before the Tribunal] respectively on the\nground that when return of income was not filed\nu/sec.139(1) of the Act it not only contravenes Sec.80IA(4)\nand, therefore, unless the assessee files its return of income\n\nu/sec.139

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

36,03,522/- for the A.Ys.2013-2014 and 2015-\n2016, [ITA.Nos.1721 & 1723/Hyd./2017 in appeals filed by\nthe assessee before the Tribunal] respectively on the\nground that when return of income was not filed\nu/sec.139(1) of the Act it not only contravenes Sec.80IA(4)\nand, therefore, unless the assessee files its return of income\n21\nITA. Nos.1721

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee

NALGONDA REALTORS PRIVATE LIMITED ,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee