2023 (2) TMI 1331

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....learned Senior Counsel representing Mr. Karthik Ramana Puttam Reddy, learned counsel for the assessees/appellants and Ms. K.Mamata Choudary, learned Standing Counsel, Income Tax Department and Ms. Sapna Reddy, learned counsel representing Mr. J.V.Prasad, learned Standing Counsel, Income Tax Department for the respondents. 3. All the related appeals have been filed under Section 260A of the Income Tax Act, 1961 (briefly referred to hereinafter as 'the Act') assailing the common order dated 21.03.2022 passed by the Income Tax Appellate Tribunal, Hyderabad Bench 'A', Hyderabad (briefly referred to hereinafter as 'Tribunal') disposing of the following appeals corresponding to the relevant assessment years: Sl.No. & Appellant ITA No. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Private Limited, Vijayawada. 686/Hyd/2020 2012-13 687/Hyd/2020 2013-14 13. Preethi Foods and Villas Private Limited, Khammam. 688/Hyd/2020 2012-13 689/Hyd/2020 2013-14 690/Hyd/2020 2017-18 4. Learned Senior Counsel for the appellant has proposed the following questions as substantial questions of law: 1. Whether on the facts and in the circumstances of the case, the Tribunal is correct in upholding the jurisdiction of the assessing officer in initiating reassessment under Section 147 of the Act overlooking the contention of the appellant that the first proviso to Section 147 of the Act is not applicable since there is full and true disclosure of all material facts necessary for assessment? ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....common order passed by the Tribunal and as agreed to by learned counsel for the parties, the appeals are taken up for final disposal at the stage of admission hearing itself. 6. In one bunch of appeals, the sole ground raised by the assessees before the Tribunal was disallowance of interest expenditure under Section 36(1)(iii) of the Act made by the assessing officer and partly affirmed by the first appellate authority. As a matter of fact, first appellate authority had granted limited relief to the assessees. For the balance relief, appeals were filed by the assessees before the Tribunal. 7. In another batch of appeals, we find that the ground urged before the Tribunal was validity of reopening of assessment proceedings under Section....