MAITHRI LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

section 2(22)(e) and keeping in view\nthe flexibility required in practical business situations, the AO treated\nthe payments made by the appellant company to the extent of 150%\nof the purchases made from the recipient companies as the payments\nmade in the ordinary course of business and the payments made in\nexcess of such

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

68,95,756 - 14,09,92,643 2020-21 5,12,22,731 3,27,38,075 1,02,22,479 48,55,404 2,67,81,999 - 12,58,20,688 2021-22 5,57,69,012 1,62,07,177 58,57,556 41,70,416 3,24,22,875 9,03,945 11,53,30,981 Total

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

68,95,756 - 14,09,92,643 2020-21 5,12,22,731 3,27,38,075 1,02,22,479 48,55,404 2,67,81,999 - 12,58,20,688 2021-22 5,57,69,012 1,62,07,177 58,57,556 41,70,416 3,24,22,875 9,03,945 11,53,30,981 Total

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeals filed by the assessee for assessment years 2019-20 and 2020-21 are partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

68,95,756 - 14,09,92,643 2020-21 5,12,22,731 3,27,38,075 1,02,22,479 48,55,404 2,67,81,999 - 12,58,20,688 2021-22 5,57,69,012 1,62,07,177 58,57,556 41,70,416 3,24,22,875 9,03,945 11,53,30,981 Total

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeals filed by the assessee for assessment years 2019-20 and 2020-21 are partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

68,95,756 - 14,09,92,643 2020-21 5,12,22,731 3,27,38,075 1,02,22,479 48,55,404 2,67,81,999 - 12,58,20,688 2021-22 5,57,69,012 1,62,07,177 58,57,556 41,70,416 3,24,22,875 9,03,945 11,53,30,981 Total

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

section 147 / 148 of the Act, the coordinate Bench had held as under : “22. Coming back to our point we have to examine whether protective assessment/addition is possible under section 147 in respect of the same person and for the same period. When a regular assessment is made and later on it comes to the notice

AGARWAL SPONGE & ENERGY PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

68,33,979/-during the financial year 2012-13. Considering the facts of the case and also the provisions of section 2(22)(e

ITO, WARD-1, KURNOOL, KURNOOL vs. S.V. MOHAN REDDY, KURNOOL, KURNOOL

In the result, appeal of the revenue is dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

section 2(22)(e). Therefore, ground No. 1 of the revenue is dismissed. 10 I.T.A. No. 483Hyd/2016 & CO 32/H/16 SV Mohan Reddy 9.1 With regard to addition u/s 68

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

e) However, a bald assertion to this effect at much belated stage cannot be accepted. Applying the aforesaid legal proposition herein, we are of the opinion that once a statement is recorded, it is open to the Assessing Officer to rely and proceed on the basis that such statement is correct and represents the true state of affairs

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

e) However, a bald assertion to this effect at much belated stage cannot be accepted. Applying the aforesaid legal proposition herein, we are of the opinion that once a statement is recorded, it is open to the Assessing Officer to rely and proceed on the basis that such statement is correct and represents the true state of affairs

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

e) However, a bald assertion to this effect at much belated stage cannot be accepted. Applying the aforesaid legal proposition herein, we are of the opinion that once a statement is recorded, it is open to the Assessing Officer to rely and proceed on the basis that such statement is correct and represents the true state of affairs

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

e) However, a bald assertion to this effect at much belated stage cannot be accepted. Applying the aforesaid legal proposition herein, we are of the opinion that once a statement is recorded, it is open to the Assessing Officer to rely and proceed on the basis that such statement is correct and represents the true state of affairs

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

2 of 42 ITA Nos 164, 194 and 195 of 2024 GRR Holdings 6. On the facts and circumstances of the case and in law, the Ld. CIT(A) ought to have appreciated that the assessee (Vendee) and vendor, both have filed affidavits regarding the non-payment and non-receipt of money on account of sale transaction

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

2 of 42 ITA Nos 164, 194 and 195 of 2024 GRR Holdings 6. On the facts and circumstances of the case and in law, the Ld. CIT(A) ought to have appreciated that the assessee (Vendee) and vendor, both have filed affidavits regarding the non-payment and non-receipt of money on account of sale transaction

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

2 of 42 ITA Nos 164, 194 and 195 of 2024 GRR Holdings 6. On the facts and circumstances of the case and in law, the Ld. CIT(A) ought to have appreciated that the assessee (Vendee) and vendor, both have filed affidavits regarding the non-payment and non-receipt of money on account of sale transaction

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

section also enumerates various circumstances under which the consideration of a contract is said to be 'unlawful'. Two such circumstances are, (i) the consideration of a contract is of such nature that, if permitted, it would defeat the provisions of any law, or (ii) the Court regards it as immoral or opposed to public policy. Hence

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

section also enumerates various circumstances under which the consideration of a contract is said to be 'unlawful'. Two such circumstances are, (i) the consideration of a contract is of such nature that, if permitted, it would defeat the provisions of any law, or (ii) the Court regards it as immoral or opposed to public policy. Hence

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

section also enumerates various circumstances under which the consideration of a contract is said to be 'unlawful'. Two such circumstances are, (i) the consideration of a contract is of such nature that, if permitted, it would defeat the provisions of any law, or (ii) the Court regards it as immoral or opposed to public policy. Hence