SIVA SHANKER REDDY GANDLURU, HYDERABAD,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

Appeals are treated as allowed for statistical purposes in above terms

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

147 of the Act which are for the benefit of the Revenue and not an assessee, an assessee cannot be permitted to convert the reassessment proceedings at his appeal or revision, in disguise, and seek relief in respect of items earlier rejected or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to escaped

SRUTHI RIEDL,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-2, HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Sruthi Riedl, Income Tax Officer, Hyderabad Vs. (International [Pan No. Aggpp6953R] Taxation)-2, Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा /Assessee By: Shri H. Srinivasulu, Ar /Revenue By: Ms. T. Vijaya Lakshmi, Cit-Dr राजस्‍वजस्‍व द्वारा सुनवाई ई की तारीखीख/Date Of Hearing: 28/08/2023 घोषणा की तारीखीख/Pronouncement On: 08/11/2023

U/s 147 as there was no capital gains chargeable to Tax in AY 2016-17 arising from the JDA dated 04.04.2007 and the JDA dated 10.02.2016 did not alter the factum of handing over of possession to the developer. 10.The Ld A.O/DRP erred in giving a finding that possession of land was given in consequences of second JDA dated

VENUGOPAL REDDY GELIVI,HYDERABAD vs. ITO (INT TAXN)-1, HYDERABAD

u/s 147 r.w.s. 144 of the Act, dated\n27-04-2023 for want of valid assumption of jurisdiction on his part\nfor initiating the assessment proceedings. As we have quashed the\nassessment for want of valid assumption of jurisdiction on the part\nof the A.O., therefore, we refrain from adverting to and adjudicating\nthe other issues, based on which

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

u/s 153C is legally bad in law and prayed for deletion of the addition made. 6.4.5 1 have gone through the assessment order, seized material, submissions of the appellant, remand report and rejoinder of the appellant. It is observed that the material seized during the search, including the sworn statements, indicates substantial evidence that the land sold in the Ameen

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

u/s 153C is legally bad in law and prayed for deletion of the addition made. 6.4.5 1 have gone through the assessment order, seized material, submissions of the appellant, remand report and rejoinder of the appellant. It is observed that the material seized during the search, including the sworn statements, indicates substantial evidence that the land sold in the Ameen

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

u/s 153C is legally bad in law and prayed for deletion of the addition made. 6.4.5 1 have gone through the assessment order, seized material, submissions of the appellant, remand report and rejoinder of the appellant. It is observed that the material seized during the search, including the sworn statements, indicates substantial evidence that the land sold in the Ameen

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

u/s 153C is legally bad in law and prayed for deletion of the addition made. 6.4.5 1 have gone through the assessment order, seized material, submissions of the appellant, remand report and rejoinder of the appellant. It is observed that the material seized during the search, including the sworn statements, indicates substantial evidence that the land sold in the Ameen

HARINATH REDDY DEVIREDDY,HYDERABAD vs. DCIT., CIRCLE 1(1), HYDERABAD

Bench: Us:

reassess the income of the appellant and consequential proceeding becomes bad in law. 5. The learned Authorities below ought to have appreciated the fact that, if at all any reasons are recorded for re-opening of assessment amount by the learned assessing officer it may amount to reason to suspect and do not amount to reason to believe

HARINATH REDDY DEVIREDDY,HYDERBAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: Us:

reassess the income of the appellant and consequential proceeding becomes bad in law. 5. The learned Authorities below ought to have appreciated the fact that, if at all any reasons are recorded for re-opening of assessment amount by the learned assessing officer it may amount to reason to suspect and do not amount to reason to believe

HARINATH REDDY DEVIREDDY,HYDERABAD vs. DCIT., CIRCLE 1(1), HYDERABAD

Bench: Us:

reassess the income of the appellant and consequential proceeding becomes bad in law. 5. The learned Authorities below ought to have appreciated the fact that, if at all any reasons are recorded for re-opening of assessment amount by the learned assessing officer it may amount to reason to suspect and do not amount to reason to believe

SANJAY KUMAR AGARWAL ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(4), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purposes

reassessment U/s. 147 is bad in law. 3. The Ld. CIT(A) ought to have considered the fact that the notice issued by the Learned A.O. U/s. 148 of the Act is invalid and bad in law, since the approval is required to be obtained from one of them i.e, either from PCIT or from CIT but the same

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

50C of the Act. We, thus, in the backdrop of the aforesaid facts,\nare of a firm conviction that the nexus between the seized material and\nthe assessee's land transaction stands established on record.\n13.\nApart from that, we find that the satisfaction note prepared by the\nAO of the searched person clearly records that the seized material\nrevealed