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

20 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 10. We have considered the submissions of both the parties and perused the material available on the record. In the present case it is not in dispute that the assessee surrendered the income of Rs. 3.64 Crores in the statement recorded under section

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

20 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 10. We have considered the submissions of both the parties and perused the material available on the record. In the present case it is not in dispute that the assessee surrendered the income of Rs. 3.64 Crores in the statement recorded under section

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

20 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 10. We have considered the submissions of both the parties and perused the material available on the record. In the present case it is not in dispute that the assessee surrendered the income of Rs. 3.64 Crores in the statement recorded under section

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

20 of 25 ITA No 446 Capgemini Technology Services India Pvt Ltd 10. We have considered the submissions of both the parties and perused the material available on the record. In the present case it is not in dispute that the assessee surrendered the income of Rs. 3.64 Crores in the statement recorded under section

PRYSMIAN CAVI E SISTEMI S.R.L,HYDERABAD vs. DCIT (INT,TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

68,78,721/-\nresulting in an addition of Rs.48,43,936/-.\n4. Aggrieved, the assessee also filed an appeal before the Ld. CIT(A)\nchallenging the consequential assessment order passed by the Ld. AO under\nsection 143(3) r.w.s. 263 dated 29.03.2006.\n5. While both the above-mentioned appeals were pending before the Ld.\nCIT(A), the Ld. AO reopened

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

68 of the I.T. Act, 1961 does not arise, because the identity of the partners was established and genuineness of the transaction was also provided. Therefore, he submitted that the addition sustained by the learned CIT (A) for the A.Y 2015-16 and 2017-18 should be deleted. 12. The learned DR, on the other hand, supporting the order

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

68 of the I.T. Act, 1961 does not arise, because the identity of the partners was established and genuineness of the transaction was also provided. Therefore, he submitted that the addition sustained by the learned CIT (A) for the A.Y 2015-16 and 2017-18 should be deleted. 12. The learned DR, on the other hand, supporting the order

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

68 of the I.T. Act, 1961 does not arise, because the identity of the partners was established and genuineness of the transaction was also provided. Therefore, he submitted that the addition sustained by the learned CIT (A) for the A.Y 2015-16 and 2017-18 should be deleted. 12. The learned DR, on the other hand, supporting the order

SREE NAGENDRA CONSTRUCTIONS,,KHAMMAM vs. DCIT, CIRCLE -2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

20,000/- from the assessee, then the addition cannot be\nmade u./s 68 of the I.T. Act, 1961. The learned CIT (A) has duly\nrecorded this fact in Para 7.3.1 as under:\n\n“The said letter was received by the AR. In response to the\nsaid letter, the assessee vide his letter uploaded in ITBA

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

68,544/- by making addition towards TP adjustment suggested by the learned TPO. 5. Aggrieved, the assessee filed objections before the Hon’ble Dispute Resolution Panel challenging the TP adjustments made by the learned TPO. The Hon’ble DRP, vide its directions issued under Section 144C(5) of the Act dated 11.09.2024, partly allowed the objections of the assessee

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

68,78,721/-\nresulting in an addition of Rs.48,43,936/-.\n4. Aggrieved, the assessee also filed an appeal before the Ld. CIT(A)\nchallenging the consequential assessment order passed by the Ld. AO under\nsection 143(3) r.w.s.263 dated 29.03.2006.\n5.\nWhile both the above-mentioned appeals were pending before the Ld.\nCIT(A), the Ld. AO reopened

ANKITJAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD.

In the result, the appeal of the assessee is allowed in\nterms of our above observation

68,750\n16-05-2019\n1,30,350\n17,88,750\n14.89.150\nCheque\nCheque\n1st Floor\n12,08,250\n10,24,630\n2nd Floor\n10,53,000\n8,83,220\n22,61,250\n19,07,850\nTotal recd\n40,50,000\n33,97,000\n7. From the above, it is clear that the assessee had purchased the property under\nquestion

SUPREME AGRO,HYDERABAD vs. ACIT CENTRAL CIRCLE-3 (1), HYDERABAD

In the result, all the appeals of assessees are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

68 without any valid reason even though it was accounted for as business income in the books of accounts of the appellant firm. 4. The ld.CIT(A) erred in upholding Assessing Officer’s computation of tax u/s 115BBE. 5. The ld.CIT(A) erred in rejecting appellant’s claim that interest u/s 234A and 234B are to be levied on returned

KANISHKA GUPTA,,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(1), HYDERABAD

In the result, all the appeals of assessees are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

68 without any valid reason even though it was accounted for as business income in the books of accounts of the appellant firm. 4. The ld.CIT(A) erred in upholding Assessing Officer’s computation of tax u/s 115BBE. 5. The ld.CIT(A) erred in rejecting appellant’s claim that interest u/s 234A and 234B are to be levied on returned

RONAK GUPTA,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(1), HYDERABAD

In the result, all the appeals of assessees are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

68 without any valid reason even though it was accounted for as business income in the books of accounts of the appellant firm. 4. The ld.CIT(A) erred in upholding Assessing Officer’s computation of tax u/s 115BBE. 5. The ld.CIT(A) erred in rejecting appellant’s claim that interest u/s 234A and 234B are to be levied on returned

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

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

INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE2(1), HYDERABAD

In the result, appeal of the Assessee for the assessment year 2021-2022 is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.943 & 1359/Hyd/2024 Assessment Years 2020-2021 & 2021-2022 Indeed India Operations The Acit, Private Limited, Vs. Circle-2(1), Hyderabad – 500 081. Hyderabad. Telangana Pan Aadci5931J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Mahima Goud, Advocate राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

68,62,731 towards interest on outstanding receivables. 2. On the facts and in the circumstances of the case and in law, the Ld. TPO erred and the Hon'ble DRP further erred in upholding/confirming the action of the Ld. TPO, in rejecting the transfer pricing analysis/study prepared by the Appellant and conducting fresh benchmarking, without appreciating that none

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

3 companies as unexplained crash credit under section 68 of the Act on the ground that, mere transfer of funds through banking channel is not sufficient to accept the claim of loan or receipt as genuine. Though the financial statements of the alleged creditors were furnished, but, the loan creditors were found to be bogus entities, particularly, floated

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

20. The careful and conjoint reading of Section 153A(1) and Section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under section 153A. 21. In the instant case, the draft assessment order