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

b) sub section (1) of section 153A within a period of 21 months from the end of the financial year in which the last of the authorizations for search u/s 132 or for requisition u/s 132A was executed. Second proviso to section 153B prescribed time limit for making the assessment or reassessment in the case of the person referred

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

b) sub section (1) of section 153A within a period of 21 months from the end of the financial year in which the last of the authorizations for search u/s 132 or for requisition u/s 132A was executed. Second proviso to section 153B prescribed time limit for making the assessment or reassessment in the case of the person referred

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ.अपी.सं / Ita Nos.1222 To 1225/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Hyderabad Pan: Ckvpa7727F (Appellant) Vs. Asstt. Commissioner Of Income Tax, Central Circle 2(4) Hyderabad (Respondent) निर्धारिती द्वारा / Assessee By: राजस्व द्वारा / Revenue By: Shri P. Murali Mohan Rao, Ca Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 22/01/2026 घोषणा की तारीख / Pronouncement: 25/02/2026 Per. Manjunatha, G. A.M. आदेश/Order 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, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

b) sub section (1) of section 153A within a period of 21 months from the end of the financial year in which the last of the authorizations for search u/s 132 or for requisition u/s 132A was executed. Second proviso to section 153B prescribed time limit for making the assessment or reassessment in the case of the person referred

ASRA AHMED ,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

b) sub section (1) of section 153A within a period of 21 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed. Second proviso to section 153B prescribed time limit for making the assessment or reassessment in the case of the person referred

SYED AHMED ZEESHANUDDIN,HYDERABAD vs. ADIT (INTERNATIONAL TAXATION)-2 , HYDERABAD

In the result, appeal filed by the assessee in I

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No.156/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2017-18)

b) sub section (1) of section 153A within a period of 21 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed. Second proviso to section 153B prescribed time limit for making the assessment or reassessment in the case of the person referred

SKYBRIDGE SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, (TP)-2 HYDERBAD, HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar(Through Virtual Mode) & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2021-22 Skybridge Solutions Vs. The Deputy Commissioner Of Private Limited, Income Tax, Hyderabad, (Transfer Pricing)-2, H.No.8-2-239/L/83-A, Hyderabad. Plot No.83/A, Mla Colony, Road No.12, Banjara Hills, Hyderabad – 500034, Telangana. Pan : Aalcs1899M. (Appellant) (Respondent) Assessee By: Shri Mahesh Raichandani, C.A. Revenue By: Ms. K. Haritha, Cit-Dr Date Of Hearing: 23.04.2024 Date Of Pronouncement: 29.04.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2021-22 Arises From The Impugned Assessment Order Passed U/S 143(3) R.W.S. 144C(3) R.W.S. 144B Of The Income Tax Act Dated 26.12.2023. 2. The Brief Facts Of The Case Are That The Assessee Is A Software Development & Services Company, Filed Its Income Tax Return For The Assessment Year 2021-22 On 09.03.2022, Declaring A Total Income Of Rs.1,06,49,030. The Return Was Processed Under Section 143(1)(A) Of The Income Tax Act On 24.08.2022. Subsequently, The Case Was Selected For Scrutiny Under Cass & A Notice Under Section 143(2) Was Issued On 28.06.2022, To Which The Assessee Responded On 15.07.2023. Thereafter, A Reference Under Section 92Ca(1) Was Made To The Transfer Pricing Officer (Tpo) To Determine The Arm'S Length Price For Transactions With Associated Enterprises. The Tpo, Through An Order Dated 31.10.2023, Directed An Upward Adjustment Of Rs.1,83,25,993 To The Assessee'S Income For The Financial Year 2020-21. Consequently, A Show Cause Notice Was Issued To The Assessee On November 9, 2023, Regarding The Proposed Adjustment, Along With A Penalty Initiation Under Section 270A.

153B], pass the assessment order under sub-section (3) within one month from the end of the month in which,- 4 (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall in a case where any objection is received under sub-section (2), issue such directions

IVY COMPTECH PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 2(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2020-21 Ivy Competech Private Limited, Vs. The Deputy Commissioner Of Income Tax, Hyderabad. Circle 2(1), Hyderabad. Pan : Aaac18884K. (Appellant) (Respondent) Assessee By: Shri Nageswara Rao, Advocate. Revenue By: Ms. M. Narmada, Cit-Dr Date Of Hearing: 20.01.2025 (Hybrid Hearing) Date Of Pronouncement: 04.02.2025

153B, the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction is received." "Section 282: Service of notice generally:- (1) The service of a notice or summon or requisition or order or any other communication under this Act (hereafter in this section referred

SYED GULAM MOHIUDDIN,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-1, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita No.136/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Syed Gulam Vs. Income Tax Officer Mohiuddin (International Taxation)-1 Hyderabad Hyderabad Pan:Decpm0365H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Assessment Order Dated 12.01.2023 Of The Learned Assessing Officer (International Taxation-1), Hyderabad, Relating To A.Y.2017-18. 2. The Grounds Raised By The Assessee Read As Under: “1. The Final Assessment Order Passed By The Income Tax Officer (Int Taxn)-1,Hyd (Herein After Referred To As 'Ao) Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant.

transferred amount towards sale consideration to M/s Skill Promoters Private Ltd through proper banking channels. 16. The Ld. A.O making a huge addition of Rs. 22,00,000/- without 16. having any documentary and corroborative evidence especially u/s 69 as unexplained investment which is baseless. 17. The Ld. A.O ought to have appreciated the fact that the assessee

TRICITIES SECURITY AND ALLIED SERVICES PRIVATE LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

SANJAY GARUDAPALLY,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

GARUDAPALLY SHRUTHI GUPTA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

KANIPAKAM HARI PRASAD REDDY,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

PULLALAREVU ANUSHA ,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

GUDURI VENKATA RAJU ,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3) , HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

TRICITIES SECURITY AND ALLIED SERVICES PRIVATE LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

GUDDURI VENKATA RAJU,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

BALLELA SAI SREE,NELLORE vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

PARIGE VENKAT RAM REDDY,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY

GARUDAPALLY SHRUTHI GUPTA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

B” PROPERTY) in the case of Harikishore Reddy Gavireddygari (ITA 4/HYD/2023). The agreement of sale in the case of all the villa owners including the appellant mentioned the minimum (in one or two case certain less things were mentioned but mostly this was the general nature of work description) of the following specifications ( page No.52 of 121 - (SCHEDULE “D” PROPERTY