THERMODYNE DYNAMICS PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD -17(3), HYDERABAD

Bench: Us :

31 Thermodyne Dynamics Private Limited Vs. ITO and has been subjected to tax under the provisions of section 56(2). These amendments are proposed to take effect from 1st June 2010 and will, accordingly, apply in relation to the assessment year 2011-12 and subsequent years. B. The provisions of section 56(2)(vii) were introduced as a counter evasion

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

transfer pricing adjustment of Rs. 13,71,40,567/- computed in respect of the transaction referred to in section 92BA(iii) & (v) read with section 80IA(8) & (10) of the Act without appreciating the jurisdictional fact that the appellant did not claim any deduction U/s. 80IA in the return of income and in that view of the matter no addition

NATEMS SOLAR POWER PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD 16(1), HYDERABAD

Bench: Us:

section 92CB of the Act and Rule 10TD, providing for Safe Harbour Rules. Safe Harbour Rules provide for certain circumstances, where the transfer price declared by an eligible assessee in respect of the specified international transactions, shall be accepted to be at arm’s length by the tax authorities. The said rules recognizes above position that loans denominated in different

VITP PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

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

transferring unlisted shares at prices much below their fair market value, it is proposed to amend section 56 to also include within its ambit transactions undertaken in shares of a company (not being a company in which public are substantially interested) either for inadequate consideration or without consideration where the recipient is a firm or a company (not being

VITP PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

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

transferring unlisted shares at prices much below their fair market value, it is proposed to amend section 56 to also include within its ambit transactions undertaken in shares of a company (not being a company in which public are substantially interested) either for inadequate consideration or without consideration where the recipient is a firm or a company (not being

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

31,23,350 employees of ZCL in France (23,41,868*133.37%) Price received by ZCL from AE 23,41,868 Adjustment u/s. 92CA 7,81,482 Thus, the arm’s length price of the taxpayer is Rs.31,23,350/- and the shortfall of Rs.7,81,482/- is treated as adjustment u/s 92CA of I.T. Act and the total income

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

31,23,350 employees of ZCL in France (23,41,868*133.37%) Price received by ZCL from AE 23,41,868 Adjustment u/s. 92CA 7,81,482 Thus, the arm’s length price of the taxpayer is Rs.31,23,350/- and the shortfall of Rs.7,81,482/- is treated as adjustment u/s 92CA of I.T. Act and the total income

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

31,23,350 employees of ZCL in France (23,41,868*133.37%) Price received by ZCL from AE 23,41,868 Adjustment u/s. 92CA 7,81,482 Thus, the arm’s length price of the taxpayer is Rs.31,23,350/- and the shortfall of Rs.7,81,482/- is treated as adjustment u/s 92CA of I.T. Act and the total income

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

31,23,350 employees of ZCL in France (23,41,868*133.37%) Price received by ZCL from AE 23,41,868 Adjustment u/s. 92CA 7,81,482 Thus, the arm’s length price of the taxpayer is Rs.31,23,350/- and the shortfall of Rs.7,81,482/- is treated as adjustment u/s 92CA of I.T. Act and the total income

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

31,23,350 employees of ZCL in France (23,41,868*133.37%) Price received by ZCL from AE 23,41,868 Adjustment u/s. 92CA 7,81,482 Thus, the arm’s length price of the taxpayer is Rs.31,23,350/- and the shortfall of Rs.7,81,482/- is treated as adjustment u/s 92CA of I.T. Act and the total income

MBS JEWELLER PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3, HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

price. Share purchase agreements with the share holder of Mis. Gold Stone Technologies Private Limited were also seized during the search. Transfer of land to assessee group is also evident from various sale deeds. :- 15 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 11. It is submitted that it is evident from the statement of Shri Sukesh

MBS IMPES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

price. Share purchase agreements with the share holder of Mis. Gold Stone Technologies Private Limited were also seized during the search. Transfer of land to assessee group is also evident from various sale deeds. :- 15 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 11. It is submitted that it is evident from the statement of Shri Sukesh

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

2) of Section 92F, where the goods or services are transferred in specified domestic transactions referred to in Section 92BA of the Act. We are of the firm conviction that now when the chilling units (i.e., eligible units) had carried out the inter-unit transfer of milk to the processing units considering the “market value” of the subject goods, which

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

2) of the Act, no order of assessment or reassessment, or re-computation shall be made under Section 147, after the expiry of 12 months from the end of the financial year in which the notice under Section 148 was served. The Learned Counsel for the assessee further submitted that, if we go by the issuance of notice under Section

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

2) of the Act, no order of assessment or reassessment, or re-computation shall be made under Section 147, after the expiry of 12 months from the end of the financial year in which the notice under Section 148 was served. The Learned Counsel for the assessee further submitted that, if we go by the issuance of notice under Section

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

2) of the Act, no order of assessment or reassessment, or re-computation shall be made under Section 147, after the expiry of 12 months from the end of the financial year in which the notice under Section 148 was served. The Learned Counsel for the assessee further submitted that, if we go by the issuance of notice under Section

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1,, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

2) of the Act, no order of assessment or reassessment, or re-computation shall be made under Section 147, after the expiry of 12 months from the end of the financial year in which the notice under Section 148 was served. The Learned Counsel for the assessee further submitted that, if we go by the issuance of notice under Section

VENKATA SUJATHA CHRUVUPALLI,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(3), HYDERABAD

In the result, the appeal of the assessee is allowed

prices of petrol, diesel and oils. 4. The appellant craves leave to add/alter/modify the grounds of appeal as may be required for proper adjudication of the case." The assessee has also raised the following additional grounds of appeal: "1. That on the facts and circumstances of the case and in law, the notice u/s 143(2) dated

YASHODA NIMMATURI,HYDERABAD vs. ACIT,CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G.A N D Shri K. Narasimha Charis.No Ita Nos. Appellant Respondent A.Y 591/Hyd/2022 Shri Ramesh Babu 1 Acit, Central Circle 2017-18 2 619/Hyd/2022 Nimmatoori Hyderabad 2(4) Hyderabad 2018-19 Pan:Acspn1659G 3 700/Hyd/2022 Acit, Central Circle 2(4) Shri Ramesh Babu 2018-19 Hyderabad Nimmatoori Hyderabad Pan:Acspn1659G 4 311/Hyd/2022 Raja Babu Nimmatoori 2013-14 589/Hyd/2022 Hyderabad Acit, Central Circle 5 2016-17 Pan:Acspn1662R 2(4) Hyderabad 6 590/Hyd/2022 2017-18 7 621/Hyd/2022 2018-19 8 701/Hyd/2022 Acit, Central Circle Raja Babu 2018-19 2(4) Hyderabad Nimmatoori Hyderabad Pan:Acspn1662R 9 337/Hyd/2022 Yashoda Nimmatoori Acit, Central Circle 2016-17 593/Hyd/2022 Hyderabad 2(4) Hyderabad 10 2017-18 618/Hyd/2022 Pan:Acspn1657J 11 2018-19 332/Hyd/2022 12 Anudeep Nimmattoori Acit, Central Circle 2016-17 13 475/Hyd/2022 Hyderabad 2(4) Hyderabad 2017-18 476/Hyd/2022 Pan:Ahbpn2081Q 14 2018-19 15 592/Hyd/2022 Sulochana Acit, Central Circle 2017-18 Nimmattoori 2(4) Hyderabad 16 620/Hyd/2022 2018-19 Pan:Acspn1664K 594/Hyd/2022 Manjusha Nimmatoori 17 Acit, Central Circle 2018-19 Hyderabad 2(4) Hyderabad Pan:Acspn1666M िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 13/06/2024 घोषणा की तारीख/Pronouncement: 14/08/2024

31 of 133 ITA Nos 591 619 700 Ramesh Babu and Others previous year in which the said certificate of completion for the whole or part of the project is issued by the competent authority, and for the purpose of section 48, the stamp duty value on the date of issue of the said certificate as increased by the consideration