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

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

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

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

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

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

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

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

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

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

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

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

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

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

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

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

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU,KADAPA vs. DCIT, CIRCLE-1(3), HYDERABAD, HYDERABAD

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 of the Act had been met by the assessee. 30. Further

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 of the Act had been met by the assessee. 30. Further

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

Bench: Us:

ii) return of income filed after 07.11.2016. Notice under Section 143(2) of the Act, dated 24.09.2018, was issued to the assessee. 3. During the course of the assessment proceedings, the AO observed that the assessee had claimed cash in hand of 4 Lakshmiramana Bandaru Rs. 40,61,284/- as on 31.03.2016, which was substantially higher than the cash

SRI KODANDARAMASWAMY PRIMARY AGRICULTURAL CO-OPERATIVE SOCIETY LIMITED,NELLORE vs. ITO., WARD-2, NELLORE

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

Bench: Shri K.Narasimha Chary

3. Assessee preferred appeal before the learned CIT(A) and argued that the amendment to Section 143(1)(a)(v) came into force with effect from 01/04/2021 and, therefore, no prima facie adjustment could be made under that section, without seeking the explanation of the assessee on any point not covered by such provision. He also argued that

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

68,02,280/- whereas the income of the assessee was computed after assessment at Rs.29,55,62,962/-as per the order passed u/s 143(3). Interestingly after the search was carried out the assessee had filed the return of income declaring ‘nil’ income and sought a refund of Rs. 40,75,88,535/-. For all the three years

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

68,02,280/- whereas the income of the assessee was computed after assessment at Rs.29,55,62,962/-as per the order passed u/s 143(3). Interestingly after the search was carried out the assessee had filed the return of income declaring ‘nil’ income and sought a refund of Rs. 40,75,88,535/-. For all the three years