ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED IMRANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

17 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 69C and 69D, the provisions of Section 115BBE are not attracted in this case. 13. The appellant had also relied upon the decision of the Hyderabad Bench of the Tribunal in the case of Mohd. Mujeeb Ur Rahman vs. ACIT in ITA No.357/Hyd/2022 dated.10.2023. The Coordinate Bench

ACIT CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED ZEESHANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

17 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 69C and 69D, the provisions of Section 115BBE are not attracted in this case. 13. The appellant had also relied upon the decision of the Hyderabad Bench of the Tribunal in the case of Mohd. Mujeeb Ur Rahman vs. ACIT in ITA No.357/Hyd/2022 dated.10.2023. The Coordinate Bench

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED IMRANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

17 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 69C and 69D, the provisions of Section 115BBE are not attracted in this case. 13. The appellant had also relied upon the decision of the Hyderabad Bench of the Tribunal in the case of Mohd. Mujeeb Ur Rahman vs. ACIT in ITA No.357/Hyd/2022 dated.10.2023. The Coordinate Bench

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. SYED IRFANUDDIN, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

17 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 69C and 69D, the provisions of Section 115BBE are not attracted in this case. 13. The appellant had also relied upon the decision of the Hyderabad Bench of the Tribunal in the case of Mohd. Mujeeb Ur Rahman vs. ACIT in ITA No.357/Hyd/2022 dated.10.2023. The Coordinate Bench

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

D. Murali, since both of them does not have any right or title over the property and also the possession of the property was not under their control. 5. The Assessing Officer after considering the relevant evidences including the copies of sale deed dated 11.02.2014 for purchase of 11.33 acres in favour of the assessee firm coupled with the statement

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

D. Murali, since both of them does not have any right or title over the property and also the possession of the property was not under their control. 5. The Assessing Officer after considering the relevant evidences including the copies of sale deed dated 11.02.2014 for purchase of 11.33 acres in favour of the assessee firm coupled with the statement

GRR HOLDINGS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(3), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

D. Murali, since both of them does not have any right or title over the property and also the possession of the property was not under their control. 5. The Assessing Officer after considering the relevant evidences including the copies of sale deed dated 11.02.2014 for purchase of 11.33 acres in favour of the assessee firm coupled with the statement

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

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 - the period of two weeks -is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. DEVENDER RAO GORUKANTI, HYDERABAD

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2021-22 Acit,Cc-2(2) Vs Devender Rao Gourkanti Room No.616,6Th Floor . H.No.8-2-293/82/Nl/231 Aaykar Bhawan Mla Mp Colony Basheerbagh Jubilee Hills Hyderabad-500 004 Hyderabad-500 033 Pan : Akepg7452N (Appellant) (Respondent) Assessee By: Shri H.Srinivasulu Revenue By: Shri K.P.R.R.Murthy, Sr.Ar Date Of Hearing: 20.03.2023 Date Of Pronouncement: 31.05.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.06.2022 Of The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad Relating To Ay 2021-22. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Partner In M/S. Yashoda Helathcare Services Pvt.Ltd & Derives Partner’S Remuneration & Interest On Capital. He Filed His Original Return Of Income On 28.12.2021 Declaring Total Income Of Rs.8,56,33,070/- A Search & Seizure Operation U/S. 132 Of The I.T. Act Was Conducted In The Case Of Yashoda Group On 22.12.2020, During Which The Case Of The Assessee Was Also Covered. In Response To Notice U/S. 153A Of The I.T.Act,The Assessee Filed His Return Of Income Admitting Additional

5,08,98,100/- as unexplained expenditure. In our opinion, the provisions of section 115BBE are applicable when the source of income is not disclosed or source of expenditure is not disclosed. However, in the instant case, the assessee has disclosed the income after considering the expenditure and had paid advance tax thereon prior to the search

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

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 - the period of two weeks -is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

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

5 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad 7. Whether the learned Authorities below are justified in denying the claim of deduction of an amount being Rs. 30,60,57,963/-, under section 801A [4] of the Act, on the pretext that the work was awarded to the Joint Venture

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

5 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad 7. Whether the learned Authorities below are justified in denying the claim of deduction of an amount being Rs. 30,60,57,963/-, under section 801A [4] of the Act, on the pretext that the work was awarded to the Joint Venture

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

5 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg Company Ltd Hyderabad 7. Whether the learned Authorities below are justified in denying the claim of deduction of an amount being Rs. 30,60,57,963/-, under section 801A [4] of the Act, on the pretext that the work was awarded to the Joint Venture

VAISHNAVI BULLION PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68 and assessed-as such, @ 60% tax irate as prescribed under provisions of section 115BBE of the IT Act.” In view of the detailed discussion above and the provisions of section 270A(9), I am satisfied that the assessee has indulged in under-reporting of income in consequence of mis-reporting of income, and accordingly, Penalty proceedings

MUSADDILAL GEMS JEWELS PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68 and assessed-as such, @ 60% tax irate as prescribed under provisions of section 115BBE of the IT Act.” In view of the detailed discussion above and the provisions of section 270A(9), I am satisfied that the assessee has indulged in under-reporting of income in consequence of mis-reporting of income, and accordingly, Penalty proceedings

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. M/S. MUSADDILAL GEMS AND JEWELS PRIVATE LIMITED, HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68 and assessed-as such, @ 60% tax irate as prescribed under provisions of section 115BBE of the IT Act.” In view of the detailed discussion above and the provisions of section 270A(9), I am satisfied that the assessee has indulged in under-reporting of income in consequence of mis-reporting of income, and accordingly, Penalty proceedings

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. VAISHNAVI BULLION PRIVATE LIMITED, HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68 and assessed-as such, @ 60% tax irate as prescribed under provisions of section 115BBE of the IT Act.” In view of the detailed discussion above and the provisions of section 270A(9), I am satisfied that the assessee has indulged in under-reporting of income in consequence of mis-reporting of income, and accordingly, Penalty proceedings

GUPTA ASHOK KUMAR,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(2), HYDERABAD

In the result, appeal of the assessee allowed

Bench: Shri Manjunatha G & Shri Ravish Sood

17 ITA.No.376/Hyd./2024 as unexplained cash credit on the basis of statement recorded from Mr. Mukesh Banka under section 132(4) of the Act at the time of search, where he has admitted to have provided accommodation entries of unsecured loans to various beneficiaries through shell/ paper companies. According to the Assessing Officer, in the list furnished