Krishnaveni Vedula Vs DCIT (ITAT Hyderabad)
Summary: The Hyderabad Bench of the Income Tax Appellate Tribunal allowed two appeals filed by Smt. Krishnaveni Vedula and Shri Bhasker Rao Vedula against separate orders passed by the Learned Commissioner of Income Tax (Appeals)-12, Hyderabad, both dated 07.08.2025, for Assessment Year 2020-21. Since the issues in both appeals were identical, they were heard together and disposed of by a common and consolidated order. In the case of Smt. Krishnaveni Vedula, the return of income for AY 2020-21 was filed on 29.12.2020 declaring total income of ₹4,72,570/-. A search and seizure operation under Section 132 was conducted on 18.01.2023 in the case of M/s. Oorjita Builders & Developers Pvt. Ltd. and its group entities, and the assessee’s case was also covered. Proceedings under Section 147 were subsequently initiated and notice under Section 148 was issued on 29.11.2023. The assessee filed a return in response on 13.01.2025, following which the Assessing Officer passed an assessment order under Section 147 dated 06.03.2025, making disallowances under Sections 80C, 24(b) and 80D and an addition on account of speculative profit. The assessed total income was ₹7,85,599/-.
Before the Tribunal, the assessee raised an additional legal ground contending that none of the additions were based on material available with the Revenue at the time reassessment proceedings were initiated and that the additions were instead based on material obtained and enquiries conducted during reassessment. The Department opposed the contention, submitting that after insertion of the new provisions of Sections 147 and 148 with effect from 01.04.2021, there was no concept of restricting reassessment only to incriminating material and that, once reassessment proceedings were validly initiated, the Assessing Officer could examine other issues coming to notice during those proceedings.
