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

reassessment order and directing an examination of the Rs. 397 crore ADS proceeds and the Rs. 1122.00 crore opening balance. A notice u/s 143(2) was issued on 30.03.2012 and served on 31.03.2012, requiring the assessee’s appearance on 09.04.2012. 21.1. In response, the assessee submitted his reply on 02.04.2012, stating that he had filed an appeal before the ITAT

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

reassessment order and directing an examination of the Rs. 397 crore ADS proceeds and the Rs. 1122.00 crore opening balance. A notice u/s 143(2) was issued on 30.03.2012 and served on 31.03.2012, requiring the assessee’s appearance on 09.04.2012. 21.1. In response, the assessee submitted his reply on 02.04.2012, stating that he had filed an appeal before the ITAT

VISWANADH KANDULA,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, appeals of the assessee for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, Dated 04/01/2023 In Case Of Exel Group Of Companies Including The Assessee For The A.Ys 2014-15 To 2019-20 Respectively. Since Common Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

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

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

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

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

Section 147 particularly the words that the Assessing Officer ''may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings'' u/s 147. The Rajasthan High Court held as follows. .... it is only when, in proceedings u/s 147 the Assessing Officer

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

37 and\n38 of the assessment order and thereby, the assessee was\nentitled to claim deduction u/sec.80IA of the Act only to the\nextent of Rs.43,04,93,491/- and the rest of the deduction\nclaimed by the assessee on account of JVs at\nRs.42,56,24,216/- shall not be allowed till the outcome of\nthe case filed

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

In the result appeals filed by the Revenue\nITA

37 and\n38 of the assessment order and thereby, the assessee was\nentitled to claim deduction u/sec.80IA of the Act only to the\nextent of Rs.43,04,93,491/- and the rest of the deduction\nclaimed by the assessee on account of JVs at\nRs.42,56,24,216/- shall not be allowed till the outcome of\nthe case filed

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

37 and\n38 of the assessment order and thereby, the assessee was\nentitled to claim deduction u/sec.80IA of the Act only to the\nextent of Rs.43,04,93,491/- and the rest of the deduction\nclaimed by the assessee on account of JVs at\nRs.42,56,24,216/- shall not be allowed till the outcome of\nthe case filed

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

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

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

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

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

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

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

37 and\n38 of the assessment order and thereby, the assessee was\nentitled to claim deduction u/sec.80IA of the Act only to the\nextent of Rs.43,04,93,491/- and the rest of the deduction\nclaimed by the assessee on account of JVs at\nRs.42,56,24,216/- shall not be allowed till the outcome of\nthe case filed

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 Ankit Jain vs. ACIT/DCIT of the Act, dated 11/12/2024, based on the Notice u/s 148 of the Act, dated 11/04/2023 issued by the DCIT, Central Circle 1(2), 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

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 Ankit Jain vs. ACIT/DCIT of the Act, dated 11/12/2024, based on the Notice u/s 148 of the Act, dated 11/04/2023 issued by the DCIT, Central Circle 1(2), 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

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

37, 38 and 39 admeasuring 500 sq yds demarcated as Plot No.445 vide document No.131/2015 on 50:50 ratio. The AO observed that the assessee was eligible for 50% built-up area, wherein her share was demarcated as Flat No.1 and Flat No.4 out of four Flats that were proposed to be constructed. 6. The AO observed that the assessee

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

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

147 has been ensured. The Hon'ble Supreme Court in Union of India v. Ashish Agarwal [(2022) 444 ITR 1 (SC)] held that where reassessment notices were issued under the old regime but during the transition to the new faceless regime, such notices shall be treated as issued under Section 148A, thereby saving reassessment proceedings from being declared void. Though