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 of the Assessing Officer

SUJIT AGARWAL ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2014-15 Shri Sujit Agarwal Vs. Dy. C. I. T. Hyderabad Central Circle 2(2) Pan:Aclpa3197P Hyderabad (Appellant) (Respondent) Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Ch V Gopinath, Cit(Dr) Date Of Hearing: 09/11/2023 Date Of Pronouncement: 22/11/2023 Order Per R.K. Panda, Vice-This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.01.2019 Of The Learned Cit (A)-12, Hyderabad Relating To A.Y.2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & The Managing Director Of The Company, M/S. Sawaria Pipes Pvt Ltd. He Filed His Original Return Of Income For The Impugned A.Y On 30.12.2014 Declaring Total Income Of Rs.20,13,600/- & Agricultural Income Of Rs.70,200/-. A Search & Seizure Operation U/S 132 Of The I.T. Act Was Conducted In The Case Of The Assessee On 12.01.2016. In Response To Notice U/S 153A Of The Act Issued On 6.9.2016, The Assessee Filed His Return

prices when the business activity of the aforesaid company was not convincing. The Assessing Officer, in the light of the above, rejected the explanation of the assessee that the share transaction in M/s. NCL Research & Financial Services Ltd were done through the broker Nirmal Bang Securities and that the payment was made through RTGS drawn on Punjab National Bank

APACHE FOOTWEAR INDIA PRIVATE LIMITED,NELLORE vs. ACIT, CIRCLE-1(1), TIRUPATI

In the result, the appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 92B, it is abundantly clear that the outstanding receivable by the assessee from its AE, is required to be benchmarked, so as to ensure that they should not be any shifting of profit from assessee to its AE. 14 Apache Footwear India Pvt.Ltd. 39. In the present case, the total turnover of the assessee in respect of Software Development

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED , HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED , HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

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

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

ACIT, CIRCLE-2(1), HYDERABAD vs. Y S JAGAN MOHAN REDDY, KADAPA

In the result, cross objection filed by the assessee is\nallowed

transfer of shares as\nagainst the value of Rs.800/- per share determined by the\nAssessing Officer.\n10. The CIT(A) ought to have appreciated the fact that the\nshares were purchased at two different rates of Rs.3001/-\nper share and Rs.1000/- per share within a span of one\nyear from two related parties and that the shares of M/s\nKealwan

MSN INSTITUTE OF MEDICAL SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

price, whereas, the final sale deed\nhas been executed for a different amount. Further, another\nstatement was found during the course of search which\ncontains details of total payment made for purchase of land\nand payment in cash and cheque and when these\nincriminating documents were confronted to the assessee\nand employees of the appellant company, they have agreed\nthat

SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, all the 4 appeals filed by the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

Price of the assessee, but said extended time limit of 12 months is not available to an eligible assessee, which is evident from wordings of section 153B and fourth proviso provided thereon. Therefore, in our considered view, the arguments of the ld. CIT-DR does not hold good and thus, the A.O ought to have completed the assessment within

SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, all the 4 appeals filed by the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

Price of the assessee, but said extended time limit of 12 months is not available to an eligible assessee, which is evident from wordings of section 153B and fourth proviso provided thereon. Therefore, in our considered view, the arguments of the ld. CIT-DR does not hold good and thus, the A.O ought to have completed the assessment within

SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, all the 4 appeals filed by the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

Price of the assessee, but said extended time limit of 12 months is not available to an eligible assessee, which is evident from wordings of section 153B and fourth proviso provided thereon. Therefore, in our considered view, the arguments of the ld. CIT-DR does not hold good and thus, the A.O ought to have completed the assessment within

ACIT., CENTRAL CIRCLE-2(3), HYDERABAD vs. SKANDHANSHI INFRA PROJECTS INDIA PVT. LTD., BANGALORE

132(1A) of the Income Tax Act, 1961.\n\n6. During the course of search and seizure operations at various premises of the assessee, after analysis of seized materials total receipts as on the date of search was prepared and the total turnover was quantified at Rs.1144 crores for Skandhanshi Group pertaining to financial year 2017-2018 to till