EXPRESSWAY SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

per the provisions of Section 153B(1), twelve months from the end of the financial year in which the last of the authorizations was executed will be up to 31.03.2022 and therefore, the assessment order passed by the A.O. under Section 153C of the Act, dated 28.03.2022 is within the time limit prescribed under Section 153B of the Act, and thus, the arguments of the learned counsel for the assessee should be rejected. 14. The Ld. CIT-DR further submitted that, as per the provisions of Section 292CC of the Income Tax Act, if a joint warrant of authorization is executed, then the assessment should be framed in the case of individual assessees, whose names are referred to in the joint warrant, however, for the purpose of computing limitation provided under Section 153B of the Income Tax Act, the last of authorization executed in the case of a person as recorded in the last panchanama drawn in relation to any person in whose case, the warrant of authorization has been issued has to be considered. In the present case, joint warrant of authorization was issued in the case of the assessee and other persons and the last of the authorization was executed as recorded in the panchanama drawn in the case of the assessee and the other associated persons on 23.07.2020 and therefore, the A.O. has rightly taken the limitation period from the end of the financial year 2020-21 and therefore, the 12 months period will come to an end on 31.03.2022. Therefore, he submitted that, there is no merit in the arguments of the learned counsel for the assessee and the same should be rejected.

12 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

13 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

14 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

assessee challenging the limitation for passing assessment order in light of date of initiation of search, date of conclusion of search as per last Panchanama drawn in the case of M/s. Prathima Infrastructure Limited.

15 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

held that: since Assessing Officer of searched party as well as Assessing Officer of third party, i.e. petitioner, was one and the same, time limit provided by first limb of clause (ii) of third proviso to section 153B(1) was to be applied, which was 12 months from end of financial year in which search took place. It was further held that since said time limit expired on 31-3-2021 and in light of TOLA and Notification No. S.O. 966(E) dated 27-2-2021, aforesaid time limit stood extended till 30-9-2021, thus, assessment under section 153C for relevant assessment years should have been completed by 30-9-2021. The interpretation by the Court fully applies to the case of the appellant. Therefore, it is necessary for us to decide the issue in light of above facts and legal position.

16 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

search, on the conclusion of search as recorded in the last panchanama drawn in relation to any person in whose case the warrant of authorisation has been issued. From the plain reading of the provisions of Section 153B(1) and Section 153B(2), it is abundantly clear that, the time limit available for the A.O. to complete the assessment is twelve months from the end of the financial year in which the last of the authorization was executed in the case of a person in whose case, the search was conducted as recorded in the last panchanama drawn. 19. In the present case, there is no dispute with regard to the fact that, the last panchanama was drawn in the case of the searched person on 12.02.2020, which is evident from the relevant panchanama which is available in the paper book filed by the assessee, wherein it has been clearly stated that, the search was finally concluded on 12.02.2020, at the places referred to in the warrant of authorization and panchanama. The learned counsel for the assessee claims that, the assessment orders passed by the A.O. under Section 153C of the Act, on 28.03.2022 for impugned assessment years are barred by limitation as prescribed under Section 153B of the Income Tax Act, because the A.O. has passed the assessment order beyond twelve months from the end of the financial year in which the last of authorization was executed. On the other hand, it was the arguments of the learned CIT-DR present for the Revenue that, the last of the authorization executed as referred to under Section 153B(2) of the Act, is the last of the authorization executed as recorded in the case of any

17 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

person in whose case, the search was conducted, as recorded in the last panchanama drawn and if we go by the above provisions, in the present case, the last of the authorization was executed on 23.07.2020, which is evident from the relevant panchanama drawn on 23.07.2020 where it was clearly stated that the search was finally concluded on 23.07.2020 after revocation of restraint order dated 08.02.2020 issued under Section 132(3) of the Act during the course of search operation at the closet of the guest room at the north-west portion of the first floor situated at the residence of Shri B. Srinivas Rao. 20. The learned CIT-DR for the revenue, referring to the provisions of Section 292CC of the Act, submitted that, if a joint warrant of authorization was issued in the case of multiple persons, although the assessment has to be framed independently in the case of each assessee, but for the purpose of computing limitation as referred to under Section 153B, the last of the authorization executed in the case of any person in whose case search was conducted as referred to in the joint warrant of authorization has to be considered. If we consider the provisions of Section 292CC and Section 153B of the Act, it is undisputedly clear that, the search was finally concluded in the case of the assessee and other associated entities/persons on 23.07.2020 which falls in the financial year 2020-21 and twelve months from the end of the financial year 2020-21 would expire on 31.03.2022 and the A.O. has rightly passed the assessment order on 28.03.2022 for all the assessment years. Therefore, it is necessary

18 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

for us to examine the issue of limitation contested by both the parties in light of facts of the present case and provisions of Section 153B r.w.s. 292CC of the Income Tax Act, 1961. 21. The time limit for completion of assessment is provided under Section 153B of the Income Tax Act, 1961 and as per Section 153B of the Act, the limitation period is twelve months from the end of the financial year in which the last of authorization was executed in the case of any person in whose case, search was conducted, as recorded in the last panchanama drawn during the course of search, in respect of search conducted on or after 01.04.2019. Section 153B(2) further clarifies that, authorization shall be deemed to have been executed in the case of search, on the conclusion of search as recorded in the last panchanama drawn in relation to any person in whose case, the warrant of authorization has been issued. From the combined reading of Section 153B(1) and 153B(2), it is undisputedly clear that, the A.O. shall get twelve months period from the end of the financial year in which the last of the authorization was executed as recorded in the last panchanama drawn in relation to the person, in whose case the warrant of authorization has been issued. Therefore, in our considered view, it is the date, on which the search was finally concluded, as recorded in the last panchanama drawn in the case of the assessee is relevant for determining the limitation period for completion of assessment as prescribed under Section 153B of the Income Tax Act, but not the last of the authorization executed in the case of any other person

19 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

in whose case search was also conducted, as recorded in the last panchanama drawn in the case of such other person, merely because the search was conducted on the basis of a joint warrant of authorization. In our considered view, the provisions of Section 292CC of the Act was specifically inserted in the statute to clarify the position of issuance of joint warrant of authorization and assessment in case of search or requisition and as per Section 292CC of the Act, it shall not be necessary to issue an authorization u/s 132 of the Act, separately in the name of each person and in case, more than one person is mentioned in the authorization, it shall not be deemed to construe that, it was issued in the name of associated persons or body of individuals consisting of such person and notwithstanding that an authorisation under Section 132 of the Act, has been issued mentioning therein the name of more than one person, the assessment or re-assessment shall be made separately in the name of each person mentioned in the name of authorisation or requisition. Therefore, from the provisions of Section 292CC of the Act, it is very clear that joint warrant of authorization can be issued mentioning more than one person and premises to be searched, however, when it comes to assessment, each one of the persons referred to in the joint warrant of authorization should be assessed separately and thus, in our considered view, once the assessment or reassessment has to be made separately on each person referred in the joint warrant of authorization, then for the purpose of computing limitation as prescribed under Section 153B of the Act, the execution of warrant in the case of each person and

20 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

recording of panchanama indicating commencement of search and conclusion of search alone is relevant for computing the limitation period, as provided under Section 153B of the Income Tax Act. Therefore, the arguments of the Revenue that, in case joint warrant of authorization was issued on more than one person and places, then the last of the authorization executed in the case of any person referred to in the joint warrant of authorization and date of conclusion of search as recorded in the last panchanama drawn in the case of any other person should be considered for the purpose of computing limitation is contrary to the scheme of assessment or reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961.

21 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

limitation for passing the assessment in the case of the assessee, should be reckoned from the date referred to in the panchanama drawn in the case of searched person, Prathima Infrastructure Limited i.e., from 12.02.2020, but not from the date of conclusion of search in the case of Sri B. Srinivasa Rao and Smt. B. Usha Rani, as recorded in the last panchanama drawn in their case on 23.07.2020 as canvassed by the learned CIT-DR for the Revenue. Further, the time limit for completion of assessment proceedings in the case of the assessee falls between 20.03.2020 and 31.03.2021. As per the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and the relevant Notification Nos. 10/2021, 38/2021 and 74/2021 issued by the CBDT, the date of completion of proceedings has been extended in view of the COVID-19 outbreak up to 30.09.2021. Therefore, in view of the provisions of Section 153B read with the TOLA Act, 2020 and the relevant notifications issued by the CBDT, the time limit available for the A.O. to complete the assessment in the present case was up to 30.09.2021, whereas the A.O. has passed the assessment order for A.Ys. 2018-19 to 2020-21 on 28.03.2022, which is beyond twelve months from the end of the financial year in which the last of the authorisations was executed. Therefore, in our considered view, the assessment order passed by the A.O. is barred by limitation and liable to be quashed.

22 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

the case of In Re: Cognizance for Extension of Limitation in MA No. 21 of 2022 in MA No. 665 of 2021 in Suo Motu W.P. (C) No. 3 of 2020 dated 10.01.2022 that the limitation provided for completion of assessment has been finally extended up to 31-05- 2022, in our considered view, the order of the Hon'ble Supreme Court is applicable to filing of suits, petitions or other judicial or quasi-judicial proceedings and therefore, the above limitation extended by the Hon'ble Supreme Court cannot be applied to the assessment proceedings which are governed by specific provisions of the Act. Therefore, in our considered view, the arguments of the Ld. CIT-DR that, in view of the outbreak of COVID and the order of Hon'ble Supreme Court, the A.O. shall get extension of time limit up to 31.05.2022 and thus, the order passed by the A.O. u/s 153C of the Act, dated 28.03.2022 is well within the limitation, is devoid of merit and cannot be accepted. Further, the Ld. CIT-DR for the Revenue has also relied upon various judicial precedents. However, in our considered view, the case laws referred to by the Ld. CIT-DR are not applicable to the facts of the present case, because in the above cases, the issue of limitation provided under Section 153B of the Act, for completion of the assessment proceedings under Section 153A in pursuant to search action conducted under Section 132 of the Act, has not been dealt with in any of the cases referred to by the Ld. CIT-DR. Therefore, we reject the arguments of the Ld. CIT-DR present for the Revenue.

23 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

assessment order passed by the A.O. under Section 153C of the Act, dated 28.03.2022 for the impugned assessment years is clearly barred by limitation as prescribed under Section 153B of the Income Tax Act, 1961, because the time limit available for the A.O., for completion of assessment under Section 153C of the Act, is 12 months form the end of the financial year in which the last of the authorisation for search under Section 132 of the Act, was conducted and in the present case, the last of the authorisation was executed in the case of M/s. Prathima Infrastructure Limited on 12.02.2020 and thus, 12 months form the end of the financial year 2019-20 would be 31.03.2021 and further, because of extension of time limit, in view of TOLA-2020 and relevant notifications issued by the CBDT, the time limit has been extended upto 30th September, 2021, whereas, the A.O. has passed the assessment order on 28.03.2022, which is clearly beyond the 12 months form the end of the relevant financial year in which last of the authorisation was executed. Thus, we quash the assessment order passed by the A.O. under Section 153C of the Act, dated 28.03.2022 for A.Y. 2018-19 to 2020-21. 25. Coming to ground No.3 of the assessee’s appeal, which challenges validity of the assessment order in light of common satisfaction notes recorded by the A.O. for Assessment Years 2014-15 to 2020-21. 26. The learned counsel for the assessee, Shri K.C. Devdas and Shri Poorna Chander, C.A., submitted that, the satisfaction recorded by the A.O. for initiation of proceedings under section

24 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

153C is generic, non-specific with regard to specific assessment- year, undisclosed income relating to each assessment year and without any reference to specific incriminating evidence and thus, the same is liable to be quashed at the threshold level. In this regard, they relied upon plethora of judicial precedents, including the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd vs. ITO (2024) 161 Taxmann.com 485 (Delhi).

25 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

decision in the case of Smt. Pavithra Sugichandran vs. DCIT (2024) 168 Taxmann.com 413 (Madras). 28. We have heard both the parties, perused relevant material on record and had gone through orders of the authorities below. The A.O. recorded a common satisfaction note for AY 2014-15 to A.Y. 2020-21 and relied upon the same for determination of the income of the appellant. The satisfaction note reads that “In view of the facts mentioned above, I am satisfied that the above seized material belongs to M/s Expressway Services Pvt. Ltd. and that the documents seized have a bearing on the determination of the total income of M/s Expressway Services Pvt. Ltd. for the assessment years 2014-15 to 2020-21”. In the above backdrop, it is necessary for us to decide the issue in light of arguments of the counsel for the assessee and counter arguments of the Ld. CIT- DR.

26 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

satisfaction with reference to incriminating materials found during the course of search and records that the materials found during the course of search in the case of searched person belongs to or relates to the other person and has a bearing on the determination of total income for relevant assessment years, the A.O. cannot proceed to initiate and issue notice u/s 153C to other person. Therefore, in our considered view, the satisfaction note must indicate undisclosed income qua incriminating materials to each assessment year separately. This contention of the appellant is supported by the decision of Hon'ble ITAT in the case of M/s. MSN Institute of Medical Sciences Pvt. Ltd., Hyderabad Telangana vs. The PCIT-(Central), Hyderabad, ITA. Nos: 1324 & 1325/Hyd/ 2024] and in Para 18 of the order the Hon'ble ITAT observed that the satisfaction note in the case was recorded in a sweeping manner without co-relating the seized material to each of the assessment years involved. It was held that such a satisfaction note does not constitute a legally valid satisfaction for the assessment years and consequently, the assumption of jurisdiction u/sec. 153C for the impugned assessment years is bad in law and unsustainable. The ITAT also placed reliance on the decision of the Apex Court in the case of CIT v. Sinhgad Technical Education Society [2017] 84 taxmann.com 290 (SC) wherein it was held that the satisfaction should be assessment year specific and incriminating evidence specific. 30. Further reliance was placed on the decision in Saksham Commodities Ltd [2024] vs. ITO 161 taxmann.com 485 (Delhi),

27 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

[SLP rejected in [2026] 182 taxmann.com 591 (SC)] wherein it was held that in Section 153C the expression "have a bearing on the determination of total income" assumes central importance. It mandates that the Assessing Officer must arrive at clear and objective satisfaction that the incriminating material gathered during the search is likely to impact the computation of total income for a specific assessment year falling within the permissible block period. Similarly, in the case of DCIT v. Sunil Kumar Sharma (2024)159 taxmann. com 179 (Karnataka), it was held the satisfaction under section 158BD [Equivalent to provisions of section 153C] should be recorded separately for each assessment year. The Hon’ble High Court found the common satisfaction note as not in accordance with the provisions of law under section 153C. SLP dismissed in [2024)168 taxmann.com 77 (SC). In the case of M/s. Calcutta Knitwears in its detailed judgement in Civil Appeal No.3958 of 2014 dated 12.03.2014 [2014] 43 taxmann.com 446(SC) it was held that the imperative need of writing a correct satisfaction highlighting the undisclosed income of the assessee is a requirement. This decision was accepted by the CBDT as contained in its Circular No. 24/2015 [F.No.279/MISC/140/2015/ITJ/DATED 31.12.2015. In the case of the appellant prima facie undisclosed income has not been specified and the same is contrary to the ratio of the judgment of the Apex Court. The decisions cited above would show that there is commonality in these decisions in as much as the essence of above decisions postulate that the satisfaction must reflect-(1) Application of mind; (2) Identification of seized material (3) Nexus

28 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

with undisclosed income; and assessment year-wise linkage. It is a settled legal proposition that if an order is bad in its inception, the same does not get sanctified at a later stage. It should be lawful at its inception, for the reason that illegality strikes at the root of order. In other words, if any legal action at the initial stage is bad in law, then all further proceedings consequent thereto will be void. A right in law exists only and only when it has a lawful origin as held in the cases of Mangal Prasad Tamoli v. Narvedoshwar Mishra (AIR 2005 SC 1964); and Ritesh Tiwari v. State of U.P. (AIR 2010 SC 3823).

29 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

the threshold level and hence the foundational requirement is wanting. The Court never specifically pronounced that satisfaction note, or the requirement of a common satisfaction note. It is a fundamental principal presence of incriminating evidence is not a requirement. It never dealt with that it is not desirable to pick a word or a sentence from a judgement and treat the same as pronouncement of law. Hence, the contention of Ld. Sr. A.R. is not acceptable. Similarly, reliance on the decision of PCIT v. Medicare (P.) Ltd 161 taxmann.com 160 (Delhi) as relied on by leaned Sr. DR is not relevant to the issues involved in appellant's case. This case related to computation of block period-whether from the date of receipt of the seized material or from the date of recording the satisfaction note. This case never dealt with the issue of recording a common satisfaction note. Reliance of Ld. Sr. A.R. on the case Smt. Pavithra Sugichandran Vs. DCIT [2024] 168 taxmann.com 413 (Madras) is also not relevant to this case. This decision is not relevant as the case never dealt with common satisfaction notes. It dealt with the issue of reckoning of limitation period. Therefore, in our considered view, case laws referred by the ld. CIT-DR/Sr. AR are not applicable to facts of this case and thus, rejected.

30 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

assessment orders for Assessment Years 2018-19 to 2020-21 are liable to be quashed. We ordered accordingly.

31 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

finally addition has been fully deleted by the ld. CIT(A). Therefore, we are not going to adjudicate the ground related to this issue. The A.O. had also made addition towards alleged cash received by the assessee from sub-contractors on the ground that it is only accommodation entry. The A.O. made additions solely on the basis of statements of employees and few sub-contractors. Except, statements, no independent evidence with the A.O. to support his findings. Therefore, in our considered view the additions made by the A.O. are not sustainable, because all expenditures were debited in the regular books of accounts and the same was subject matter of statutory audit. The report of the auditor is unqualified. There is no whisper in the assessment order that the statutory report of the C.A., was defective in the light of material omission or commission by the appellant. That audit reports prepared under statutory obligation constitute material which can be taken into consideration by authorities has held in the case of Additional CIT v. Jay Engineering Works Ltd., 113 ITR 389.

32 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

bank account of Appellant and the bank accounts of recipient entities. All the sub-contractors are assessed to tax and claimed credit for TDS in their assessments on the basis entries in Form No.26AS. The most relevant provision is Section 114 of The Indian Evidence Act, 1872, which stipulates that the Court may presume that Judicial and official acts have been regularly performed. No evidence was found to show that cash was returned by these entities to Appellant. Mere oral statements by few sub-contractors will not meet the requirements of law. No cash or any undisclosed asset was found from the office of Appellant or its directors or in any other place regarding receipt of cash from these entities. The Director, in his statement, has denied any execution of work through bogus subcontractors. It is imperative to appreciate that except for bringing to his notice the statements of some persons, no documentary evidence regarding receipt of cash from sub- contractors was brought to his notice as there was none discovered or in the possession of Department. 36. An assessment under section 153C of the Act is required to be based on tangible evidence pointing to undisclosed income for which the case was reopened. As stated above, nothing comes out of the satisfaction note. Hence, any addition on suspicion or surmise or in a general manner is not sustainable in an assessment made under section 153C of the Act, which should be incriminating evidence specific and undisclosed income specific. The provisions of section 153C of the Act, cannot enlarge the scope of addition, going beyond the reasons for which the case

33 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

was reopened under section 153C. In the course of comprehensive search of the premises of Prathima group, including the appellant and the Directors, no evidence was found incriminating the appellant. Consequently, the jurisdiction to assess or reassess should be read in a restricted manner in such circumstances, i.e., the jurisdiction to assess or reassess ought to be restricted to only incriminating material unearthed during the course of search after following the due procedure. It is also relevant to refer to the decision in the case of PCIT, Central-3 Vs. Abhisar Buildwell P. Ltd. [2023] 149 taxmann.com 399/293 Taxman 141 (SC), no addition could be made in the absence of incriminating evidence. The requirement of presence of incriminating evidence is more pronounced in the case of a 153C proceeding which lays down the boundary of jurisdiction. Merely based on contradicting statements of a few sub-contractors and one accountant against a total of more than 50 sub-contractors and not supported by any kind of incriminating material like unexplained money, bullion, jewelry, books of accounts or other records etc. no addition can be made. It may be relevant to mention here that on the basis of statement recorded under section 132(4) of the Act, no addition can be made without corroboration. There is unanimity among the Courts and Tribunals that a standalone statement admitting income may not fall within the scope of undisclosed income. A statement cannot be equated with a document or asset. It cannot be said that an oral statement was seized during the course of search as held in the case of CIT v. Harjeev Aggarwal [2016] 70 taxmann.com 95 (Delhi).

34 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

35 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

Mangeshkar [1974] 97 ITR 696 (Bom) is a landmark ruling on the use of third-party evidence in tax assessments. The court held that entries in a third party's books of accounts. statements, or loose papers cannot form the sole basis for an addition unless corroborated by primary or direct evidence. It emphasized that unverified oral testimony is unreliable. Furthermore, the Court stressed the importance of affording the assessee an opportunity to cross-examine third parties whose statements are relied upon, reinforcing the principles of fair play and due process in tax proceedings. In our considered view, the Revenue has got a tendency to make an addition on the basis of entries appearing in the books of a third party or a statement recorded from a third party or loose papers seized from a third party. In all such cases, it is imperative to afford an opportunity for the assessee to cross- examine the said third party. In this case, despite request to give opportunity for cross examination of adverse witnesses, the same was not acted upon. This contradicts the fundamental doctrine of audi alteram partem that no person should be condemned unheard. In this regard, it is relevant to refer to the decisions of the Apex Court in the cases of Kishanchand Chellaram v. CIT 125 ITR 713 (SC) and Andaman Timber Industries v. CCE [2015] 62 taxmann.com 3/52 GST 355 (SC) (2015) 94 CCH 0187 ISCC. In both cases the assessment was declared void as no opportunity was given to cross-examine the adverse witness.

36 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

the A.O. towards alleged cash received from the sub-contractors as income from other sources on the basis of statement of third parties without there being any corroborative evidences cannot be sustained. The Ld. CIT(A) without appreciating the relevant facts, simply upheld the addition made by the A.O. Thus, we direct the A.O. to delete the additions made towards alleged cash received from the sub-contractors as income from other sources for all the assessment years.

Order pronounced in the Open Court on 27th March, 2026.

Sd/- श्री विजय पाल राि Sd/- (मंजूनाथ जी) (VIJAY PAL RAO) उपाध्यक्ष /VICE PRESIDENT (MANJUNATHA G.) लेखा सदस्य/ACCOUNTANT MEMBER Hyderabad, dated 27.03.2026. TYNM/sps

37 ITA Nos.484 to 486/Hyd/2025 Expressway Services Pvt. Ltd.

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:- Expressway Services Private Limited, D-Block, 4th 1. निर्धाररती/The Assessee : Floor, Wing-1, Cyber Gateway, Shaikpet, Madhapur B.O., Telangana – 50081. 2. रधजस्व/ The Revenue : The Deputy Commissioner of Income Tax, Central Circle 2(4), Hyderabad. 3. The Principal Commissioner of Income Tax (Central), Hyderabad. 4. नवभधगीयप्रनतनिनर्, आयकर अपीलीय अनर्करण, हैदरधबधद / DR, ITAT, Hyderabad 5. गधर्ाफ़धईल / Guard file

आदेशधिुसधर / BY ORDER Digitally signed by TIRUPATI TIRUPATI YAMINI YAMINI NAGA MALLESWARI NAGA MALLESWARI Date: 2026.03.27 16:57:30 +05'30' Sr. Private Secretary ITAT, Hyderabad