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of <h1>Tribunal partially allows appeal on reassessment, sends notional interest issue back for review. Reopening reasons not relevant.</h1> <h3>Ramya Constructions Limited, Vijayawada Versus Deputy Commissioner of Income Tax, Central Circle-2 (3), Hyderabad</h3> Ramya Constructions Limited, Vijayawada Versus Deputy Commissioner of Income Tax, Central Circle-2 (3), Hyderabad - TMI Issues:1. Reopening of assessment under section 147 of the Income Tax Act, 1961.2. Addition of notional interest on redeemable debentures.Reopening of Assessment:The case involved an appeal by the assessee against an order passed by the Learned Commissioner of Income Tax(Appeals)-12, Hyderabad. The assessee challenged the additions and the reopening of the assessment. The Ld. CIT(A) held that there were valid reasons and material for the reopening, citing relevant case laws. The Ld. CIT(A) dismissed the appeal on the addition towards interest on redeemable debentures. The Tribunal found that the reasons for reopening did not disclose any material related to the assessee, and the proceedings were independent of the search conducted on another company. The Tribunal upheld the initiation of proceedings under section 147, dismissing the appeal on the reopening issue.Addition of Notional Interest on Redeemable Debentures:Regarding the addition of notional interest on redeemable debentures, the Ld. AR argued that the addition was based on estimates and surmises without concrete evidence. The assessee contended that no interest was received on debentures, and the amount transferred to other companies was mistakenly shown as debentures. The Ld. CIT(A) and the Ld. DR supported the Assessing Officer's decision. The Tribunal noted that similar issues were addressed in a case involving group companies and decided to restore the matter to the Assessing Officer for further examination. The Tribunal allowed the ground related to the addition of notional interest on redeemable debentures for statistical purposes, following the decision in the case of group companies.In conclusion, the appeal of the assessee was partly allowed for statistical purposes, with the Tribunal upholding the reopening of assessment under section 147 and restoring the issue of notional interest on redeemable debentures for further examination by the Assessing Officer.
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