PRYSMIAN CAVI E SISTEMI SRL INDIA PROJECT OFFICE (FORMERLY PIRELLI CAVI SISTEMI S P A INDIA PROJECT OFFICE),HYDERABAD vs. DCIT,( INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

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

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

143(3) r.w. section 153C of the Income-tax Act, 1961, dated 31.05.2021, is invalid and bad in law. 21. Before proceeding further, we deem it apposite to cull out the provisions of Section 153D of the Act as had been made available on the statute vide the Finance Act, 2007 w.e.f. 01.06.2007, as under: "153D. No order

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

143(3) r.w. section 153C of the Income-tax Act, 1961, dated 31.05.2021, is invalid and bad in law. 21. Before proceeding further, we deem it apposite to cull out the provisions of Section 153D of the Act as had been made available on the statute vide the Finance Act, 2007 w.e.f. 01.06.2007, as under: "153D. No order

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

143(3) r.w. section 153C of the Income-tax Act, 1961, dated 31.05.2021, is invalid and bad in law. 21. Before proceeding further, we deem it apposite to cull out the provisions of Section 153D of the Act as had been made available on the statute vide the Finance Act, 2007 w.e.f. 01.06.2007, as under: "153D. No order

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

143(3) r.w. section 153C of the Income-tax Act, 1961, dated 31.05.2021, is invalid and bad in law. 21. Before proceeding further, we deem it apposite to cull out the provisions of Section 153D of the Act as had been made available on the statute vide the Finance Act, 2007 w.e.f. 01.06.2007, as under: "153D. No order

ANJANEE VIJETHA KASTURI,KURNOOL vs. ACIT, CIRCLE-1, KURNOOL

In the result, appeal of assessee is allowed

Bench: Shri K. Narasimha Chary

68, section 69, section 69A, section 69B, section 69C or section 69D of the Act in the order passed under section 143(3

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

143(3) r.w.s. Section 144C(13) of the Act by the Assessment Unit pursuant to invalid directions passed by the Hon'ble DRP is illegal and therefore null and void and liable to be quashed. 3. Software Development (‘SWD’) Services Segment (Tax Effect: ₹83,31,809/-) 3 M/s. Callidus Cloud (India) Private Limited 3.1. On the facts

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

143(3) r.w. section\n153C of the Income-tax Act, 1961, dated 31.05.2021, is invalid and bad\nin law.\n21. Before proceeding further, we deem it apposite to cull out the\nprovisions of Section 153D of the Act as had been made available on\nthe statute vide the Finance Act, 2007 w.e.f. 01.06.2007, as under:\n\"153D

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

Section 143(3) of the Income-Tax Act, 1961 on 14.03.2025. During the course of assessment proceedings, it was noticed that, the assessee had proposed to purchase a plot admeasuring 194.5 sq. yards at Madhapur and had incurred expenditure of Rs.67,39,500/- through banking channels towards purchase and Rs.22,88,000/- in cash towards development of the property

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

Section 143(3) of the Income-Tax Act, 1961 on 14.03.2025. During the course of assessment proceedings, it was noticed that, the assessee had proposed to purchase a plot admeasuring 194.5 sq. yards at Madhapur and had incurred expenditure of Rs.67,39,500/- through banking channels towards purchase and Rs.22,88,000/- in cash towards development of the property

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

Section 143(3) of the Income-Tax Act, 1961 on 14.03.2025. During the course of assessment proceedings, it was noticed that, the assessee had proposed to purchase a plot admeasuring 194.5 sq. yards at Madhapur and had incurred expenditure of Rs.67,39,500/- through banking channels towards purchase and Rs.22,88,000/- in cash towards development of the property

SYED WARISUDDIN NAVEED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

Section 143(3) of the Income-Tax Act, 1961 on 14.03.2025. During the course of assessment proceedings, it was noticed that, the assessee had proposed to purchase a plot admeasuring 194.5 sq. yards at Madhapur and had incurred expenditure of Rs.67,39,500/- through banking channels towards purchase and Rs.22,88,000/- in cash towards development of the property

SYED WARISUDDIN NAVEED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

Section 143(3) of the Income-Tax Act, 1961 on 14.03.2025. During the course of assessment proceedings, it was noticed that, the assessee had proposed to purchase a plot admeasuring 194.5 sq. yards at Madhapur and had incurred expenditure of Rs.67,39,500/- through banking channels towards purchase and Rs.22,88,000/- in cash towards development of the property

RAGHUNATH REDDY GANGARAM,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2),, HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

Section 143(3) of the Income-Tax Act, 1961 on 14.03.2025. During the course of assessment proceedings, it was noticed that, the assessee had proposed to purchase a plot admeasuring 194.5 sq. yards at Madhapur and had incurred expenditure of Rs.67,39,500/- through banking channels towards purchase and Rs.22,88,000/- in cash towards development of the property

MADHAVA REDDY BADDEVOLU,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

Section 143(3) of the Income-Tax Act, 1961 on 14.03.2025. During the course of assessment proceedings, it was noticed that, the assessee had proposed to purchase a plot admeasuring 194.5 sq. yards at Madhapur and had incurred expenditure of Rs.67,39,500/- through banking channels towards purchase and Rs.22,88,000/- in cash towards development of the property

R.A.K CERAMICS INDIA PRIVATE LIMITED,SAMALKOT vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

143(3) read with Sections 144C (13) of the Act\nto the extent prejudicial to the Appellant, is bad in law and is liable to be quashed.\nOn the facts and in the circumstances of the case and in law, the final assessment order passed\nby the Assistant Commissioner of Income-tax Circle-3(1), Hyderabad is without jurisdiction

LAKSHMIRAMANA BANDARU,KADAPA vs. ITO., WARD-1, KADAPA

Bench: Us:

143(3) r.w Section 254 of the Income-tax Act, 1961 (for short, “the Act”), dated 30.04.2021. The assessee has assailed the impugned order on the following grounds of appeal before us: “1). The addition of Rs. 40,61,283/- to the returned income is incorrect and not justified when the appellant has proved the sources and explained

DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD vs. BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU, YSR DIST., YSR DIST.

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

143 (3) of the Act in the matters of these shareholders show that the Ld.AOs of the shareholders did not doubt their bona fide existence or the genuineness of their transaction with the assessee. Hence, in our considered view, all the three ingredients set out in Section 68