IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “A” BENCH: HYDERABAD BEFORE SHRI MANJUNATHA G, ACCOUNTANT MEMBER AND SHRI RAVISH SOOD, JUDICIAL MEMBER Assessment Year 2016-2017 Sri Naveen Kumar Musinipally, USA, Resident of 133/4, R.P. The ADIT [INT-TAXN]-1, vs.

Road, SECUNDERABAD. Hyderabad.

PIN 500 003. Telangana.

PAN APEPM4130Q (Appellant) (Respondent)

For Assessee : CA, K C Devdas For Revenue : Sri Posu Babu Alli, Sr. AR Date of Hearing : 20.08.2025 Date of Pronouncement : 15.10.2025 ORDER PER MANJUNATHA, G.

This appeal has been filed by the assessee against the Order dated 09.02.2024 of the learned Commissioner of Income Tax (Appeals)-10, Hyderabad, relating to assessment year 2016-2017.

2. The assessee has raised the following grounds in the instant appeal :

“Under the facts and circumstances of the case, 1. The order of the Commissioner of Income Tax Appeals -10, Hyderabad (The Ld.CIT(A)') in confirming the taxation of long term capital gains arising on the development agreement under section 153C r.w.s 144C(3) of the Income Tax Act 1961 ('the Act') in the subject AY is unsustainable both on facts and in law.

A. LEGAL GROUNDS

2. The learned CIT(A) failed to appreciate that the Ld.AO u