DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra

KAVYA BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. JHANSI RANI BOPPANA, HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. TARA CHAND BOPPANA, HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. KAVYA BOPPANA, HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

ACIT, CENTRAL CIRCLE-2(3), HYDERABAD vs. SARAT GOPAL BOPPANA, HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3),, HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

TARA CHAND BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

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

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

153A of the Act on 29.09.2021 and determined the total income at Rs.4,47,29,559/- by making various additions, including addition towards unaccounted cash receipts towards sale of commercial space in Sarat City Capital Mall, capital gain on sale of property, addition towards capital gain by invoking provisions of Section 50C of the Income

VIVIMED LABS LIMITED,HYDERABAD vs. 500082 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

Transfer Pricing Officer’s “TPO” section 92CA(3) orders dt.29.01.2016 and 31.10.2016; respectively. Suffice to say, the impugned search action took place thereafter on 09.11.2016 followed by the DRP’s directions dt.20.12.2016 in A.Y. 2012-13. Both these assessments thereafter stood treated as “abated” ones in light of section 153A

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE2-(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

Transfer Pricing Officer’s “TPO” section 92CA(3) orders dt.29.01.2016 and 31.10.2016; respectively. Suffice to say, the impugned search action took place thereafter on 09.11.2016 followed by the DRP’s directions dt.20.12.2016 in A.Y. 2012-13. Both these assessments thereafter stood treated as “abated” ones in light of section 153A

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX , HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

Transfer Pricing Officer’s “TPO” section 92CA(3) orders dt.29.01.2016 and 31.10.2016; respectively. Suffice to say, the impugned search action took place thereafter on 09.11.2016 followed by the DRP’s directions dt.20.12.2016 in A.Y. 2012-13. Both these assessments thereafter stood treated as “abated” ones in light of section 153A

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

Transfer Pricing Officer’s “TPO” section 92CA(3) orders dt.29.01.2016 and 31.10.2016; respectively. Suffice to say, the impugned search action took place thereafter on 09.11.2016 followed by the DRP’s directions dt.20.12.2016 in A.Y. 2012-13. Both these assessments thereafter stood treated as “abated” ones in light of section 153A

AUROBINDO PHARMA LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYD, HYDERABAD

In the result, appeal of the assessee is allowed

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

Transfer Pricing Officer (TPO) on 3/1/2014. Ld. TPO by order dated 29/1/2015 determined the Arms Length Price (“ALP”) of the international transaction at Rs. 27,39,76,704/- on account of adjustment in respect of writing off of accrued interest on loans and writing off of bad debts. 3. Consequently a draft assessment order was passed on 31/3/2015 under section

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

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

153A, the issuance of notice under section 21 Sanghi Textiles Privarte Limited vs. ITO 143(2) of the Act is not mandatory will equally apply with the same force for framing of an assessment on a return of income filed by an assessee in response to notice issued under section 148 of the Act. 23. We have given thoughtful consideration

VIVIMED LABS LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX 2(3), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

Transfer Pricing Officer’s “TPO” section 92CA(3) orders dt.29.01.2016 and 31.10.2016; respectively. Suffice to say, the impugned search action took place thereafter on 09.11.2016 followed by the DRP’s directions dt.20.12.2016 in A.Y. 2012-13. Both these assessments thereafter stood treated as “abated” ones in light of section 153A