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

74,50,000/- although the entire cash deposits are of the same genre of business. 5. The ld.CIT(A) erred in law in confirming the AOs findings that the provisions of section 68

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

74,50,000/- although the entire cash deposits are of the same genre of business. 5. The ld.CIT(A) erred in law in confirming the AOs findings that the provisions of section 68

AGARWAL INDUSTRIES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

74 establish creditworthiness of (SC)/[2019] 412 investor companies, Assessing ITR 161 (SC) Officer was justified in passing assessment order making additions under section 68

ACIT., CIRCLE-5(1), HYDERABAD vs. NET NET VENTURES PVT LTD, HYDERABAD

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

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.385/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Asst. Commissioner Of Income Tax, M/S. Net Net Ventures Pvt. Ltd., Vs. Hyderabad. Circle 5(1), Hyderabad. Pan:Aabcn2106L (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri V. Siva Kumar, Advocate रधजस् व द्वधरध/Revenue By: Ms. U Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 28/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By The Revenue (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 09.01.2025 For The A.Y. 2018-19. 2. The Revenue Has Raised The Following Grounds Of Appeal :

74,46,450/- under section 69 of the Act. Accordingly, the Ld. AO completed the assessment by making two additions of Rs.1,73,51,631/- under section 68

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

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

SHANKAR LAL AGARWAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-16(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri K. Narasimha Chary

Section 68 of the Act. Thus, the assessees cannot be permitted to contend that the assessments were based on surmises and conjectures or Page 17 of 27 presumptions or assumptions. The assessee does not and cannot dispute the fact that the shares of the companies which they have dealt with were insignificant in value prior to their trading

ANIRUDH VENKATA RAGI ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

Section 68 of the Act. Thus, the assessees cannot be permitted to contend that the assessments were based on surmises and conjectures or presumptions or assumptions. The assessee does not and cannot dispute the fact that the shares of the companies which they have dealt with were insignificant in value prior to their trading. If such is the situation

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, ANANTAPUR vs. SAVEERA HOSPITAL PRIVATE LIMITED, ANANTAPUR

In the result, appeals of the Revenue are accordingly allowed and consequently the cross objections preferred by the assessee are dismissed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

68 of the Act. 9. Aggrieved by such deletion of the additions, the Revenue is before us in these appeals contending that the primary onus to prove the shareholders creditworthiness lies on the assessee in view of the judgement of the Hon’ble Apex Court in the case of CIT Vs. Lovely Exports Private Limited

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, ANANTAPUR vs. SAVEERA HOSPITAL PRIVATE LIMITED , ANANTAPUR

In the result, appeals of the Revenue are accordingly allowed and consequently the cross objections preferred by the assessee are dismissed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

68 of the Act. 9. Aggrieved by such deletion of the additions, the Revenue is before us in these appeals contending that the primary onus to prove the shareholders creditworthiness lies on the assessee in view of the judgement of the Hon’ble Apex Court in the case of CIT Vs. Lovely Exports Private Limited

PUJALA MAHESH BABU,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

PUJALA MAHESH BABU ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD vs. PUJALA MAHESH BABU , RANGA REDDY

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

PUJALA MAHESH BABU ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

PUJALA MAHESH BABU,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आयकर अपीलसं./I.T.A. No.1083/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2017-18) Assistant Commissioner Of Income Tax, Circle-5(1), Hyderabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) Industries आयकर अपीलसं./I.T.A. No.1084/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2018-19) Assistant Commissioner Of Income Tax, Circle-5(1), Hydeabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Industries Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By : Shri Sourabh Soparkar, Advocate राजस्वकाप्रतिनिधित्व/ Department Represented By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing : 11/11/2025 घोषणा की तारीख/ Date Of Pronouncement : 21/01/2026 2

74,92,000/-; (ii) disallowance of the claim of the assessee company for deduction under section 80G w.r.t CSR donations: Rs. 1,88,97,644/-; (iii) disallowance of the claim of deduction of the assessee company under Section 801A of the Act: Rs. 24,35,05,411/-; and (iv) addition under section 68

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

74,92,000/-; (ii) disallowance of the claim of the assessee company for deduction under section 80G w.r.t CSR donations: Rs. 1,88,97,644/-; (iii) disallowance of the claim of deduction of the assessee company under Section 801A of the Act: Rs. 24,35,05,411/-; and (iv) addition under section 68