ACIT Vs Net Net Ventures Pvt. Ltd (ITAT Hyderabad)
ITAT Hyderabad Partly Allows Revenue Appeal – Repayment to Net Net Web Treated as Regrouping, Other Issues Remanded
Hyderabad Tribunal delivered order in Revenue’s appeal against CIT(A) order dated 09.01.2025 in the case of Net Net Ventures Pvt. Ltd., a real estate company.
1.Repayment to Net Net Web (₹7.00 Cr)
- AO treated closing balance of ₹7,00,98,081/- shown in FY 2016-17 under “Other Current Liabilities” as repaid in FY 2017-18 & taxed u/s 69.
- CIT(A) found no repayment; it was mere regrouping from “Other Current Liabilities” to “Unsecured Loans.” Verified through audited statements & bank accounts.
- Tribunal upheld CIT(A) – no actual repayment; addition deleted
2. Repayment to Mr. G. Amrender Reddy (₹1.47 Cr)
- AO added repayment as unexplained, ignoring assessee’s evidence.
- Assessee had filed ledger, confirmation, & bank statements showing receipt & repayment through banking channels.
- Tribunal remitted issue to AO for fresh verification
3. Increase in Unsecured Loans (₹1.73 Cr)
- AO added as unexplained u/s 68.
- Assessee had filed ledgers & confirmations of three loan creditors, but AO did not verify.
- CIT(A) deleted addition citing AO’s lapse.
- Tribunal remanded back to AO for verification of identity, creditworthiness & genuineness
Tribunal’s Decision
- Repayment to Net Net Web (₹7.00 Cr) – Addition deleted.
- Repayment to Amrender Reddy (₹1.47 Cr) – Remanded.
- Unsecured loans increase (₹1.73 Cr) – Remanded.
- Revenue’s appeal partly allowed for statistical purposes
FULL TEXT OF THE ORDER OF ITAT HYDERABAD
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