आयकर अपीलीय न्यायाधिकरण में , हैदराबाद ‘बी’ बेंच , हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad , , श्री विजय पाल राि माननीय उपाध्यक्ष एिं श्री मंजूनाथ जी माननीय लेखा सदस्य SHRI VIJAY PAL RAO, HON’BLE VICE PRESIDENT AND SHRI MANJUNATHA G, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No.1277/Hyd/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16)

Unique Rail Road Vs. The Deputy Commissioner of Consultants Private Limited, Income-tax, Hyderabad. Circle – 1(3), Hyderabad.

PAN : AAACU8136E (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

करदाता का प्रतततितित्व/ : Shri P. Murali Mohan Rao, Assessee C.A.

Represented by राजस्व का प्रतततितित्व/ : Shri Ashutosh Pradhan, Sr.

Department Represented by A.R.

सुिवाई समाप्त होिे की ततति/ : 11.12.2025 Date of Conclusion of Hearing घोर्णध की तधरीख/ : 19.12.2025 Date of Pronouncement

O R D E R

PER MANJUNATHA G., A.M :

This appeal filed by the assessee is directed against the order of the learned Commissioner Income Tax (Appeals) – 12, Hyderabad, dated 12.06.2025, pertaining to the assessment year 2015-16.

2. The grounds raised by the assessee read as under :

“1. The order of the CTT(A) passed u/s 250 of the Act dated 12-06- 2025 is erroneous both on facts and in law to the extent the order is prejudice to the interests of the appellant.

2. The Ld. CIT(A) erred in upholding the additions made by AQ without properly appreciating the facts of the case and appellant's submissions.

3. The Ld. CIT(A) ought to have considered that the Ld. AO has completed the assessment as that of complete scrutiny without following the guidelines of the CBDT, even though the case was, selected for limited scrutiny

4. The Ld. CIT(A) erred in confirming the ad-hoc disallowances without identifying specific bogus expenses.

5. The Ld. CIT(A) ought to have appreciated the fact that the assessment order passed u/s 143(3) of the Act dated 29-12-2017 was issued in the name of a non-existent entity, rendering the order void-ab-initio.

6. The Ld. CIT(A) erred in dismissing the ground stating that the AO was not informed but legal existence of an assessee is a jurisdictional fact and the AO should have verified PAN or ROC records.

7.The Ld. CIT(A) erred in not appreciating that the return of income was filed subsequent to the amalgamation, and hence, the assessment ought to have been made in the name of the amalgamated entity, United Rail Road Consultants Private Limited, rather than in the name of the non-existent entity.

8. The Ld. CIT(A) erred in upholding the disallowance made by AO without considering the fact that the appellant has maintained books of accounts as per the provisions of section 44AB of the Act.

9. The Ld. CTT(A) ignored the fact that the AO failed to verify specific bogus bill/vouchers and made a blanket 10% disallowance of Travel & Tour expenditure and Vehicle Hiring charges, without rejecting books of accounts and is bad in law.

10. The Ld. CIT(A) erred by not appreciating the fact that the AO did not verify the ledger entries or cross examine the bifurcation of expenses and simply disallowed Rs. 19,43,388/- alleging double claim under “Other expenses” and “Cost of Execution” on presumption and without having any evidence with him.”

3. The brief facts of the case are that, the assessee is a company engaged in the business of providing consultancy services, filed its Return of Income for F.Y. 2015-16 on 29.09.2015, admitting total income of Rs. 2,29,74,860/-. The case was selected for scrutiny through CASS to verify the large other expenses claimed in the profit and loss account and mismatch in sales turnover reported in audit report and ITR. During the course of assessment proceedings, the A.O. noticed that, the assessee has debited a sum of Rs. 3,31,08,852/- under the head Travels and Tours expenses. The A.O. called upon the assessee to produce bills and vouchers in support of expenses. In response, the assessee has submitted the bills in support of Travels and Tours expenses. The assessee claimed