Manchala Ravinder Alias Raviendra Vs DCIT (ITAT Hyderabad)
Summary: In Manchala Ravinder alias Raviendra v. DCIT, ITA No. 1078/Hyd/2025 (AY 2016-17), order dated 21.08.2026, the Hyderabad ITAT dealt with disputes concerning capital gains and business income. The assessee claimed ₹6.50 lakh as commission/transfer expenses on property sales, but the claim rested on self-made debit vouchers and complete particulars, including addresses of the alleged recipients, were not furnished; the Tribunal therefore upheld the disallowance. It also sustained rejection of development/improvement expenditure of ₹42.89 lakh allegedly incurred during 2006–2010 towards land levelling, blasting, rock cutting, JCB charges and labour expenses because supporting evidence was not produced and the assessee did not establish through an impounding order or other material that the relevant records were with the Department. The developer’s response to the Section 133(6) enquiry also disclosed no specific development expenditure. The Tribunal similarly sustained rejection of the residential-house exemption claim for want of supporting documentary evidence. However, on the computational issue, the assessee’s original return disclosed a business loss of ₹5,42,616, whereas the revised return showed business income of ₹1,06,02,100; the assessee contended that land-sale, salary and rental amounts included in net profit were again separately offered under their respective heads. Finding prima facie substance in the contention and noting that the CIT(A) had not adjudicated the ground, the ITAT restored this issue to the AO for verification and reframing of the assessment. The appeal was partly allowed for statistical purposes.
