GIRIDHARIS CONSTRUCTIONS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(1), HYDERABAD

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ITA 2090/HYD/2026Status: DisposedITAT Hyderabad18 September 2026AY 2018-1937 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal directed the AO to estimate 15% profit on unaccounted cash receipts and income. Additions made under Section 68 for unsecured loans were sustained, but the benefit of telescoping was allowed against income from estimated profits.

What were the facts?

The assessee company and the Revenue filed appeals against the orders of the CIT(A) concerning assessment years 2014-15 to 2019-20. The appeals involved common issues regarding unaccounted receipts and cash credits.

What were the issues?

The primary issues were the estimation of income from unaccounted receipts and the treatment of unexplained cash credits under Section 68, including the applicability of telescoping benefits.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE,Section 153A,Section 153C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad “A” Bench, Hyderabad

For Respondent: DR Seema Meena

आदेश / ORDER

PER MANJUNATHA G., A.M : The captioned appeals filed by the assessee company and the Revenue are directed against the separate orders passed by the Ld. Commissioner of Income Tax (Appeals)-11, Hyderabad, dated 24.10.2025, relating to the assessment years 2014-15 to 2019-20. The assessee has filed six appeals for the assessment years 2014- 15 to 2019-20, whereas the Revenue has filed two appeals for the assessment years 2017-18 and 2018-19. Since common issues are involved in all these appeals, the same were heard together and are being disposed of by this single consolidated order for the sake of convenience and brevity.

2.

The assessee company has raised more or less common grounds of appeal in all the assessment years. Therefore, for the sake of brevity, ITA No.2089/Hyd/2026 for A.Y. 2017-18 is taken as lead appeal and its grounds are re-produced as under:

“1. The order passed by the Learned CIT (Appeals) is against the law as well as on the facts of the case. 2. On the facts and circumstances of the case, the Learned CIT(Appeals) erred in directing the Assessing Officer to treat 25% of the unaccounted receipts as income derived and accordingly arrive at taxable income.

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3.

On the facts and circumstances of the case, the Learned CIT(Appeals) would have observed that estimation of profit @25% of the unaccounted receipts is higher in the business filed of the appellant company and hence would have accepted the submissions of the appellant to tax only 15% of such receipts as income. 4. On the facts and circumstances of the case, the Learned CIT(Appeals) would have appreciated that only a real income need to be considered for taxation but not the entire gross receipts. 5. On the facts and circumstances of the case, the estimation of 25% of the unaccounted receipts as income by the Learned CIT(Appeals) is without any basis and not supported by any comparative cases. 6. On the facts and circumstances of the case, the Learned CIT(Appeals) ought to have considered the expenses incurred as per the seized document numbered page 158 and 159 of Annexure A/KIR/RES/01 which is almost 85% of such receipts and therefore would have estimated 15% of unaccounted receipts as income or real income has to be computed. 7. On the facts and circumstances of the case, the Learned CIT(Appeals) is not justified in not considering the ground of the appellant for adjudication with regard to treating the unaccounted sale receipts/income as unexplained and taxing the same as per the provisions of Section 115BBE of the I.T.Act. 8. On the facts and circumstances of the case, the Learned CIT(Appeals) is not justified in upholding the addition made of Rs.50,80,000/- to tax as unexplained cash credit u/s.68 of the I.T.Act. 9. On the facts and circumstances of the case, the Learned CIT(Appeals) is not justified in confirming the action of the Assessing Officer in making addition U/s 68 without finding and basing on any incriminating material that was found during the course of search proceedings. 10. On the facts and circumstances of the case, the Learned CIT(Appeals) is not justified in confirming the registered value of Villa No.23 of Rs.27,81,000/- as income and also estimating the income @ 25% on the balance amount of Rs.1,12,19,0000/- as reasonable income without any basis and citing any comparable cases. 11. On the facts and circumstances of the case, the Learned CIT(Appeals) ought to have appreciated that notice u/s.153A of the Act issued is invalid since the Page 2 of 3 documents on which the addition made was seized from the premises of other concerns of the group and no incriminating material was found in the premises of the appellant which is relevant for making assessment in the hands of the appellant.

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12.

On the facts and circumstances of the case, the Learned CIT(Appeals) ought to have upheld the plea that if the documents seized from the residential premises of the Director (With separate panchanama) are considered to be belonging to the assessee company, then the only legal recourse available to the department to proceed against the assessee is in terms of section 153C of the Act and the said materials cannot be used against the assessee in the assessment u/s 153A. 13. The Appellant craves leave to add, amend, alter, vary and/or withdraw any or all the above grounds of appeal.”

3.

At the outset, there is a delay of 167 days in filing the present appeals before the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay. The learned counsel for the assessee, Shri M.V. Prasad, C.A., referring to the affidavit filed by the assessee, submitted that, the impugned orders passed by the learned CIT(A), dated 25.10.2025, were received by the assessee and the appeals were required to be filed on or before 31.12.2025. However, the appeals came to be filed on 12.06.2026, resulting in a delay of 167 days in filing the appeals before the Tribunal.

4.

It was further submitted that, the delay in filing the appeals was neither wilful nor deliberate but occurred due to unavoidable circumstances beyond the control of the assessee. The learned counsel for the assessee submitted that, the assessee-company had changed the e-mail ID used for correspondence with the Income Tax Department and, consequently, the orders passed by

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the learned CIT(A.) did not come to the notice of the assessee immediately. It was submitted that the assessee came to know about the disposal of the appeals only when the Assessing Officer issued attachment notices under section 226(3) of the Act, for recovery of taxes. Thereafter, the orders were downloaded from the Income Tax portal and steps were taken to file further appeals before the Tribunal. It was further submitted that, during the relevant period, the CEO of the assessee-company suffered from severe back pain and was advised bed rest for a period of eight weeks from 06.04.2026 to 10.06.2026, which further delayed the filing of the appeals. The learned counsel for the assessee also relied upon the decision of the Hon'ble Supreme Court in the case of Vidya Sankar Jaiswal vs. Income Tax Officer, in Civil Appeals Nos. 26310-26311/2024, dated 31.01.2025, in support of the plea for adopting a liberal and justice-oriented approach while considering the condonation of delay. Accordingly, it was prayed that the delay of 167 days in filing the appeals before the Tribunal may kindly be condoned in the interest of justice.

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5.

The learned CIT-DR for the Revenue, Ms. Seema Meena, on the other hand, opposed the condonation petitions filed by the assessee. She submitted that, the assessee has failed to file the appeals within the prescribed period and, therefore, the delay may not be condoned. However, she fairly submitted that, the issue may be decided in accordance with law on the basis of the facts and material available on record.

6.

We have heard both the parties, perused the petitions and affidavits filed by the assessee seeking condonation of delay of 167 days in filing the appeals before the Tribunal. We find that, the reasons explained by the assessee appear to be genuine and bona fide and come under 'sufficient cause'. We further find that, the Hon'ble Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji, reported in 167 ITR 471 (SC), has laid down certain principles for condoning the delay and directed that a lenient approach should be followed to avoid dismissal of meritorious cases on technical grounds. Going by the principles laid down in Mst. Katiji (supra), and also considering the submissions of the assessee, including the reliance placed on the decision of the Hon'ble Supreme Court in the case of Vidya Sankar Jaiswal

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(supra), we condone the delay of 167 days in filing the appeals before the Tribunal and admit the appeals for adjudication.

7.

The brief facts of the case are that, the assessee company, engaged in the business of construction and sale of residential villas, filed its return of income for A.Y. 2017-18 on 22.03.2018, admitting total income of Rs. 13,71,390/-. A search and seizure operation u/s. 132 of the Income-tax Act, 1961 was conducted on 26.04.2018 in the case of Giridhari Constructions and associated companies. During the course of search, at the residential premises of K. Indrasena Reddy, certain loose sheets and documents were found and seized as per Annexure A/KIR/RES/1, containing pages from 1 to 182. The seized documents, particularly pages 158 and 159, contained information regarding the sale of villas in the project, including customer number, villa number, extent in SFT, total cost, cash received, cheque received and balance amount. The total amount of cash received as per the seized loose sheets was computed at Rs. 3,87,89,973/-, out of which an amount of Rs. 2,39,84,000/- was deposited in the bank. The balance amount of Rs. 1,48,05,973/- was shown as expenses incurred towards the project. The Managing Director of the

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assessee company, K. Indrasena Reddy, in his statement recorded on 26.07.2018 u/s. 132(4) of the Act, has admitted additional income of Rs. 1,88,05,973/- spread over four assessment years starting from A.Y. 2014-15 to 2017-18.

8.

Consequent to search, a notice u/s. 153A of the Act, dated 07.01.2019 was issued and served on the assessee company. In response, the assessee company filed its return of income on 23.03.2019, admitting total income of Rs. 13,71,390/-. The case was selected for scrutiny and, during the course of assessment proceedings, the A.O. noted that in the return of income filed in response to the notice issued u/s. 153A of the Act, the assessee company had admitted the same income as declared in the return filed u/s. 139(1) of the Act. The A.O. further noted that, the assessee company had not disclosed the additional income admitted at the time of search amounting to Rs. 17,34,440/-. Therefore, the A.O. issued a show-cause notice and called upon the assessee company to explain as to why an addition should not be made towards unaccounted cash receipts received from the sale of residential villas. In response, the assessee company submitted that, it was engaged in the business of real estate development and

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was under compulsion to accept part of the consideration in cash, as many customers insisted on the same. It was further submitted that, the cash received from the sale of residential villas was incurred towards various expenditure, including expenditure for development of the project, and that the same was recorded in the very same seized material. Therefore, the assessee company submitted that, the income surrendered during the course of search in the statement recorded u/s. 132(4) of the Act, was not based on any material and requested the A.O. to make a reasonable estimate of net profit. In this regard, the assessee company relied upon certain judicial precedents, including the decision of the Hon’ble Madhya Pradesh High Court in the case of CIT v. Sharda Real Estate Pvt. Ltd., 99 DTR 100 (MP), and the decision of the Hon’ble Andhra Pradesh High Court in the case of CIT v. Rajapushpa Properties, ITTA No. 531 of 2013, order dated 31.10.2013. The assessee company also explained the other seized material, including the loan transactions with various parties.

9.

The A.O., after considering the relevant submissions of the assessee and also taking note of the statement recorded during the course of search, observed that, although the assessee had

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admitted unaccounted cash received from the sale of flats, but it failed to disclose the said unaccounted receipts in the return of income filed in response to notice u/s. 153A of the Act. The A.O. further noted that the assessee had not filed any retraction statement with necessary evidence to prove that the initial admission of undisclosed income of Rs. 17,34,440/- towards unaccounted cash receipts was incorrect. Therefore, the A.O. rejected the explanation of the assessee and considered the unaccounted sale consideration of Rs. 1,47,54,835/- for the assessment year under consideration. After considering the admission of additional income of Rs. 17,34,440/-, the A.O. made an addition of Rs. 1,30,20,395/- towards the balance amount of unaccounted sale consideration received from the sale of flats. The A.O. also made an addition of Rs. 1,40,00,000/- towards unaccounted sales income from the sale of Villa No. 23, on the ground that the assessee had not offered the sale consideration in respect of the said villa, which was registered on 06.12.2016 in favour of Sri Manoj Kumar. Thus, the A.O. made an addition of Rs. 1,30,20,395/- towards the balance unaccounted sale consideration from the sale of villas and an addition of Rs. 1,40,00,000/- towards unaccounted sales consideration in

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respect of Villa No. 23. The A.O. had also made an addition of Rs. 50,80,000/- towards unexplained unsecured loans received from various persons, including Sri A. Srinivasa Reddy, Sri P.S. Sharma, Sri Bhupal Reddy and Sri Hari Babu, as the assessee failed to prove the identity, creditworthiness and genuineness of the transactions.

10.

Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee filed detailed written submissions on the issue, which have been reproduced at para 5.1 on pages 27 to 71 of the Ld. CIT(A)’s order. The sum and substance of the arguments before the Ld. CIT(A) was that the initial admission of undisclosed income towards unaccounted cash receipts from the sale of flats was not based on any evidence which could be considered for the purpose of making additions, and further, the assessee had admitted additional income without verifying the records, including the relevant expenditure incurred out of unaccounted cash receipts. Therefore, the assessee submitted that, a reasonable amount of profit may be estimated by considering the nature of business of the assessee and judicial precedents on this issue, including the decisions of

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the Hon’ble Andhra Pradesh High Court and the Hon’ble Madhya Pradesh High Court. The assessee also challenged the additions made by the A.O. towards unaccounted cash sales of Rs. 17,34,440/-, unexplained unsecured loans of Rs. 50,80,000/- under Section 68 of the Act, difference in sale consideration of Rs. 1,30,20,395/-, and unaccounted sale consideration relating to Villa No. 23 of Rs. 1,40,00,000/-, and argued that, since the present assessment was unabated, the additions made by the A.O. could not be sustained. In this regard, the assessee relied upon the decision of the Hon’ble Supreme Court in the case of Principal CIT (Central-3) v. Abhisar Buildwell P. Ltd., reported in [2023] 149 taxmann.com 399 (SC).

11.

The Ld. CIT(A), after considering the submissions of the assessee and also taking note of various evidences found during the course of search, including relevant seized material, which contains details of unaccounted cash receipts and unaccounted expenditure, directed the A.O. to estimate 25% profit on the unaccounted cash receipts of Rs. 17,34,440/- and the difference in sale consideration of Rs. 1,30,20,395/-. In so far as the unaccounted sale consideration relating to Villa No. 23, the Ld.

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CIT(A) treated the registered sale consideration of Rs. 27,81,000/- as income and directed the A.O. to estimate 25% profit on the balance amount of Rs. 1,12,19,000/-. The relevant findings of the Ld. CIT(A) are as under :

“6. Decision: 6.1. Appellant company derives income from Real Estate Business, construction and sale of flats. The original Return of Income for the impugned A.Y. 2017-18 was filed on 22.03.2018 admitting Total Income of Rs.13,71,390/-. A Search & Seizure operation was conducted in the case of M/s. Giridhari Constructions on 26.04.2018 and as a part of Search operation, warrant u/s 132 was executed on the appellant company. During the course of Search & Seizure operation in the case of MD of the appellant company, certain loose sheets and documents were seized as per Annexure No. A/KIR/RES/1 containing pages from 01 to 182. Page No. 158 & 159 contained information regarding sale of Villas in the project ‘Villa Onyx’ such as customer name, Villa number, area in sq. feet, total cost, cash received, cheque received and balance. 6.2. Notice u/s 153A dated 07.01.2019 was issued and served on the appellant, in response, appellant filed Return of Income on 23.03.2019 admitting Total Income of Rs.13,71,390/-. Subsequently, notices u/s 142(1) were issued from time to time calling for certain information. After examining the details furnished by the appellant AO concluded the assessment u/s 153A of the Act on 27.04.2021 making the following additions. i. Rs.17,34,440/- on account of unaccounted income – Cash sales. ii. Rs.50,80,000/- on account of unexplained cash credits – Unsecured loans iii. Rs.1,30,20,395/- on account of unaccounted income – Difference in sales. iv. Rs.1,40,00,000/- on account of unaccounted sales. 6.2.1. Aggrieved by the additions made by the AO, appellant filed the present appeal.

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6.3. Appellant raised 17 Grounds of Appeal, out of which Grounds of Appeal No. 1 to 5, 10 & 17 are general in nature and need no separate adjudication. In Ground of Appeal No. 6, appellant contended that AO erred in bringing an amount of Rs. Rs.50,80,000/- to tax as unexplained cash credit u/s 68 of the IT Act without any incriminating material. In Ground of Appeal No.7, appellant submitted that the case laws quoted by AO are distinguishable since they are not related to any Search proceedings. In Ground of Appeal No.8, appellant submitted that during the course of Search there is no material found indicating that the unsecured loans are not genuine. In Ground of Appeal No.9, appellant contended that AO is not justified in making the additions towards unsecured loans as these are infused through banking channels. In Ground of Appeal No. 11, it is contended that AO did not appreciate that Rs.17,34,440/-, Rs.1,30,20,395/- and Rs.1,40,00,000/- represents cash receipts an there is difference between receipt and income. In Ground of Appeal No. 12, it is contended that AO failed to consider the corresponding expenditure incurred by the appellant company was also not recorded in Books of Account. In Ground of Appeal NO. 13, appellant submitted that AO ought to have considered that whenever evidence is found in respect of suppression of receipts, the AO has to make an estimation of income on such suppressed receipt and not to addition entire receipts. In Ground of Appeal No.14, it is submitted that AO failed to follow the decisions of Ju risdictional High Court of AP in the case of CIT Vs Rajapusha Properties in ITTA no. 531 of 2013. In Ground of Appeal No.15, it is contended that AO should have not considered the statement recorded u/s 132(4) of the IT Act as conclusive evidence for framing assessment. In Ground of Appeal No. 16, it is contended that AO has not considered the plea of the appellant to estimate the income from such receipts at 15% thereof as corresponding cash expenses were also found during Search. 6.3.1. The assessment order, Grounds of Appeal and Written Submissions made by the appellant have been carefully examined. 6.4. The Grounds of Appeal are adjudicated as follows. 6.5. Grounds of Appeal No. 11 to 16: 6.5.1. Addition of Rs. 17,34,440/- on account of unaccounted income – cash sales” 6.5.1.1. During the course of Search & Seizure operation in the case of MD of the appellant company, certain loose sheets and documents were seized as per Annexure No. A/KIR/RES/1 containing pages from 01 to 182. Page No. 158 & 159 contained information regarding sale of Villas in the project ‘Villa Onyx’ such as customer name, Villa number, area in sq. feet, total cost, cash received, cheque received and balance.

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6.5.1.2. The Managing Director of the Company Sri K Indrasena Reddy in sworn statement recorded u/s 132(4) stated that out of cash received of Rs.3,87,89,973/- in the project ‘Villa Onyx’ an amount of Rs. 2,39,84,000/- was deposited in the bank account and the same was reflected in the Books of Account, the balance amount of Rs. 1,48,05,973/- was not shown in the Books of Account. Further, it was also stated that Rs.40,00,000/- shown as ‘Hari Sir loan’ in Page No. 158 was also received by way of cash and the same was not reflected in the Books of Account. Later, Sri K Indra sena Reddy filed affidavit on 23.08.2018 and voluntarily admitted additional income of Rs.1,88,05,973/- (Rs.1,48,05,973/- + Rs. 40,00,000/-) for different A.Y. as follows: Asst. Year Additional Income admitted in Rs. 2014-15 18,07,362 2015-16 43,32,180 2016-17 1,09,31,991 2017-18 17,34,440 Total 1,88,05,973 6.5.1.3. During assessment proceedings, AO issued show cause notice proposing to make the addition. Appellant responded stating that due to business compulsion in the field of real estate, part of consideration was accepted as cash as many customers insist on the same. Such receipts were not accounted in the regular books and utilised for finishing works and amenities. The existence of expenditure over and above the expenses recorded in regular Accounts was evident from seized material. 6.5.1.4. Further, appellant relied upon decisions of Hon'ble Courts in the following mentioned cases. “Kishor Mohanlal Telwala v. Asstt. CIT (1999) 64 TTJ (Ahd) 543 CIT v. Sharda Real Estate Pvt Ltd 99 DTR 100 (MP) CIT Vs Rajapushpa Properties in ITTA No.531 of 2013 (AP) CIT Vs Sri Rao Shiva Kumar in ITTA No 215 of 2014 (AP)” 6.5.1.5. Further, appellant submitted that what is chargeable in respect of on-money or unaccounted turnover is only the profits embedded in such turnover. However, AO did not accept the submissions of the appellant and relied upon decisions of Hon'ble Courts as mentioned below and held that statements recorded u/s 132(4) have greater evidentiary value and cannot be disregarded. “M/s. Bannalal Jat Constructions Pvt Ltd vs ACIT (2019) (106 Taxmann.com 128 CIT, Bikaner vs Ravi Mathur, 2017 (1) WLC (Raj.) 387 Pr. CIT vs Roshan Lai Sancheti in ITA.No.47/2018 dated 30.10.2018”

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Accordingly, AO made addition of Rs.17,34,440/- for impugned A.Y. 2017-18 as unaccounted income – cash sales. 6.5.2. Addition of Rs.1,30,20,395/- on account of unaccounted income – difference in sales. 6.5.2.1. During the course of Search & Seizure operation in the case of MD of the appellant company, certain loose sheets and documents seized as per Annexure No. A/KIR/RES/1 containing pages from 1 to 182 page no 158 & 159 contained information regarding sale of villas in the project ‘Villa Onyx’ such as customer name, Villa No. area in Sq. feet, total cost, cash received, cheque received and balance. During assessment proceedings appellant furnished a statement containing details of name of Villa purchaser, Villa number, total SFT, date of registration, sale agreement amount, development amount and total pertaining to Assessment Year 2016-17, impugned 2017-18 & A.Y. 2019-20. The information furnished by the appellant was cross verified with the seized documents Page No. 158 & 159 of Annexure No. A/KIR/RES/1 by the AO and it was noticed that the appellant had recorded only part of total sale consideration received in its Books of Account and there was difference in sales recorded in the Books of Account and sale as per seized document for the impugned A.Y. 2017-18. For the impugned A.Y. 2017- 18, AO noticed that Rs.1,47,54,835/- was not recorded in the Books of Account. Accordingly, it was held that appellant suppressed sale consideration and treated the said amount as unaccounted income. Further, since Rs.17,34,440/- was already considered as unaccounted cash sales (as discussed in para No 6.5.1.5), AO deducted Rs.17,34,440/- from Rs.1,47,54,835/- and treated Rs.1,30,20,395/- as unaccounted income – difference in sales. 6.5.3. Addition of Rs. 1,40,00,000/- on account of unaccounted sales: 6.5.3.1. From the seized page No. 158 & 159 of Annexure No. A/KIR/RES/1. AO inferred that sale consideration of Seven Villas of Rs.9,15,49,198/- viz. Villa No.s 3,11,12,13,16,23 & 40 all admeasuring 3030 Sq.Ft each was not accounted in regular Books of Account. AO also arrived the rate per Sq.Ft at Rs.4,200/-. During assessment proceedings, appellant submitted that out of seven villas, only sale consideration of two villas 12 & 23 were not recognised as sales in books of accounts. Sale deed for Villa No. 23 was executed for an amount of Rs.27,81,000/- on 06.12.2016 and sale deed for Villa No. 12 was executed on 10.05.2017 for an amount of Rs.27,81,000/-. From the information submitted by the appellant, AO noticed that Villa No. 23 registered on 06.12.2016 to one Sri Manoj Kumar was pertaining to impugned A.Y. 2017-18 and sale consideration of Rs.1,40,00,000/- (as per MOU dated 08.06.2016 of Page No. 75 of A/KIR/RES/1) was not accounted in the

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Books of Account. Therefore, Rs.1,40,00,000/- was considered as unaccounted sales and brought under ambit of tax. 6.5.4. With regard to addition of Rs.17,34,440/- during appellate proceedings, appellant submitted that Villas sold by the appellant company were at semi-finished stage and a separate agreement will be entered for carrying out necessary civil works to make such semi-finished Villas into fully completed residential units. The construction agreed upon for a sale of residential unit and the construction work are duly entered in respective agreement / deeds, the total consideration paid by a customer for a villa is split into two components viz consideration for sale of immovable property representing semi-finished unit and consideration for finishing works and other amenities. The revenue in respect of sale of Semi-finished unit is recognised on execution of sale deed and whereas the revenue relating to construction agreement is recognised on proportionate complete basis. During the Search operation conducted certain loose sheets were seized, as per information contained in Page 158 & 159 of such sheets, a portion of consideration amount of Rs.3,87,89,973/- was received in cash out of which Rs.2,39,84,000/- was deposited in the bank accounts and reflected in regular Books of Account. The remining amount of Rs.1,48,05,973/- received in cash and another amount of Rs.40,00,000/- received in cash were not entered in regular accounts. Further, appellant also submitted that it is a business compulsion in the field of real estate to accept the part of the consideration as cash as many of the customers insist on the same. Thus, appellant company was forced to accept a portion of consideration for finishing works and amenities in cash in order to survive in the competitive market. Not only such receipts but lot of relatable expenditure was also not accounted for in the regular Books of Account and such expenditure would be equivalent to unaccounted receipts. It was further stated that the factum of existence of expenditure over and above the expenses recorded in regular accounts was also evident from the seized papers from which the details of unaccounted receipts were gathered. It was also submitted that AO did not discuss about such expenses nor brought out any evidences to the effect that such expenditure was already recorded in Books of Account are proved them as bogus. Further, it was submitted that AO did not consider the explanation of the appellant, during assessment proceedings, agreeing for adaptation of profit at the rate of 25% of the undisclosed receipts as income. Relying on the decision of Hon’ble High Court of Gujarat in the case of CIT Vs President Industries [2002] 258 ITR 654 Gujarat, appellant argued that entire undisclosed sales cannot constitute income and profit component embedded in the sales could be treated as income. Appellant relied upon the decision of High Court of Madhya Pradesh in the case of CIT Vs Balchand Ajit Kumar to submit that only net profit should be adopted as income. Further, appellant submitted that Hon'ble ITAT B Bench in the case of ITO Ward- 16(2) Hyderabad Vs Neelima Estates Pvt Ltd. in ITA No. 1646 & 1650/HYD/2014 directed the AO to calculate the additional income at

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the rate of 12% on the additional receipt by giving leverage for expenditure of 88%. Further, appellant contended that AO erroneously treated the unaccounted receipt as unaccounted income and levied tax as per provisions of Section 115BBE of the Act. The receipts represent sales and derived during the course of sale of flats and hence cannot be treated as receipts from unexplained sources. 6.5.5. Appellant made similar submission with regard to additions of Rs. Rs.1,30,20,395/- & Rs.1,40,00,000/- 6.5.6. The submission of the appellant have been carefully perused. 6.6. The sum and substance of the submissions made by the appellant are that the sale consideration received in cash represents business receipts and entire receipts cannot be considered as income and only profit component embedded in such receipts can be amenable for taxation. At this juncture, it is relevant to study the decisions of Hon'ble courts on the issue of taxing only the profit component and not entire sale receipts. 1.In the case of CIT Vs. Willamson Financial Services [2007] 165 taxman 638, Hon’ble Supreme Court made an observation as below: “It is important to bear in mind that u/s. 4, the levy is on total income of the assessee computed in accordance with and subject to the provisions of the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts. ” In the case of CIT Vs. Willamson Financial Services, Hon’ble Apex Court had laid down a fundamental principle. The principle is that, income is arrived at after allowing admissible expenditure such as the cost of the purchases and incidental expenses against receipts. b. In the case of CIT Vs. President Industries [2002] 124 taxman 654 (Gujarat) Hon’ble High Court of Gujarat has held as below: “The amount of sales by itself cannot represent the income of the assessee who has not disclosed the sales. The sales only represent the price received by the seller of the goods for the acquisition of which it has already incurred the cost. It is the realization of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that the investment by way of incurring cost in acquiring goods which has been sold has been made by the assessee and that has also not been disclosed, the question whether entire sum of undisclosed sales proceeds can be treated as

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income, answers by itself in the negative. As a result, no question of law arose out of the Tribunal Appellate order.” The Hon’ble Gujarat High Court in the case of CIT Vs. President Industries held that the entire undisclosed sales cannot constitute income. The sales only represent price received by the seller of the goods for which it has already incurred the cost. Therefore, it is a realization of excess consideration over the cost incurred which should be assessed as profit or income. In this case net profit rate was applied to undisclosed income. c. The ratio of the decision by Hon’ble High Court of Gujarat in the case of CIT Vs President Industries was followed by Hon’ble High Court of Madhya Pradesh in the case of CIT Vs. Balchand Ajit Kumar [2004] 135 taxman 180 wherein it was held that the net profit should be adopted as income. It was also observed that the rate of profit, high or low, would depend on the facts of the case. In Balchand Ajit Kumar case Hon’ble High Court of Madhya Pradesh held as follows: “The total sale cannot be regarded as the profit of the assessee. The net profit rate has to be adopted and once a net profit rate is adopted it cannot be said that there is perversity of approach. Whether the rate is low or high it would depend upon the facts of each case. In the instant case net profit rate of 5% applied by the Tribunal was not required to be enhanced. It was also not high. In any case, there was no perversity of approach. In view of the aforesaid there was no merit in the appeal and the same should dismissed.” d. In the case of Sampada Homes, Hyderabad Vs. ACIT Central Circle- 2(3), Hyderabad in ITA No.s 95 to 97/Hyd/2018, the Hon’ble Jurisdictional ITAT, Hyderabad had held that the entire turnover cannot be brought to tax as such and there can be reasonable profit estimation on the turnover amount. e. In the case of ACIT Central Circle-2(3), Hyderabad Vs. Sri Sri Estates Hyderabad in ITA Nos. 228 to 230/Hyd/18 Hon’ble Jurisdictional ITAT held that: “13.1. Respectfully following the decision, we are of the opinion that the entire turnover cannot be brought to tax as such and there can only be an estimation of reasonable profit on the so called suppressed turnover. Therefore, there is no merit in Revenue grounds, accordingly, they are dismissed.” In this case of Sri Sri Estates Hon’ble ITAT held that the amount of sales by itself cannot represent the income of the assessee. It is the realization

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of excess over the cost incurred that only forms part of the profit included in the configuration of the sale. f. In the case of Skill Promotors Hyderabad Vs ACIT, Central Circle-2(3), Hyderabad Hon’ble ITAT B Bench held that 15% of unaccounted receipts is reasonable profit rate in cases of assessee’s engaged in business of construction and land development. 6.7. From the decisions of the Hon’ble Courts mentioned supra a definite ratio emerges that the entire unaccounted turnover cannot be brought to tax and as such there can only be a reasonable estimation of net profit on the unaccounted turnover. In respect of unrecorded sales, it is imperative that expenses would have been incurred though not recorded. Therefore, computation of profit after inclusion of unaccounted sales in the turnover would necessarily require deduction of unrecorded expenses. Problem arises in cases where the expenditure cannot be identified in clear terms, in such cases Hon’ble Courts have taken the view that there is a presumption of expenditure having been incurred in respect of unrecorded sales. In other words, only profit component embedded in the sales could be treated as income. 6.8. In the present case, it is noticed that the appellant had received sale consideration in cash which were not recorded in Books of Account. As far as the s ource of the cash receipts are concerned, it is clear that the receipts are from the sale of the flats. AO had considered entire cash sales as additional income without giving any margin for expenditure. In the nature of business of the appellant, it is common that certain expenditure is also incurred in cash. Further, as per seized loose sheet No.158 in A/KIR/RES/1, there were expenditure recorded therein. But, however, appellant could not furnish supporting documents / evidences in support of such expenditure made. In such facts, circumstances and nature of the business in which appellant is engaged, it can be said that the entire sale receipts cannot be considered as unaccounted income. As discussed above, Hon'ble Courts have held that only profit component embedded in sales could be treated as income. In view of the totality of the facts and circumstances of the case and to meet both ends of justice 25% of unaccounted cash sales / unaccounted difference in sales of Rs.17,34,440/- & Rs.1,30,20,395/- is estimated as income. Accordingly, AO is directed to add only 25% of the unaccounted cash sales / unaccounted difference in sales and not entire suppressed sales. 6.9. Further, with regard to addition of Rs.1,40,00,000/-, it is noticed that Villa No. 23 was registered for Rs.27,81,000/- on 06.12.2016. Appellant submitted that out of Rs.1,40,00,000/-, the amount over and above Rs.27,81,000/- represents additional works carried out by the appellant. In this regard, it is presumed that the expenditure relatable to Rs.27,81,000/- which is value of the Villa reflected in sale deed is already inbuilt in the expenditure claimed in the Books of Account and

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hence the said amount of Rs.27,81,000/- should be entirely considered as income and no margin of expenditure would be available. However, the remaining portion of sale consideration Rs.1,12,19,000/- (Rs.1,40,00,000/- (–) Rs.27,81,000/-) cannot be entirely considered as income for the reasons discussed above. Therefore, AO is directed to consider only 25% of Rs.1,12,19,000/- as income and remaining amount shall be deleted. 6.10. In view of the above discussion, Grounds of Appeal No. 11,12 13 & 15 are allowed, and Grounds of Appeal No.14 & 16 are partly allowed.”

12.

In so far as the addition made by the A.O. towards unexplained unsecured loans of Rs. 50,80,000/- under Section 68 of the Act, the Ld. CIT(A) observed that, the assessee had not furnished any evidence to prove the identity, creditworthiness and genuineness of the transactions, except stating that the additions could not be made in an unabated assessment. But the fact remains that, the assessment year under consideration was an abated assessment year, and there was no restriction on making additions in abated assessments in the absence of incriminating material. Therefore, the Ld. CIT(A) rejected the explanation of the assessee and sustained the addition made by the A.O. towards unsecured loans under Section 68 of the Act, as unexplained cash credits.

13.

Aggrieved by the order of learned CIT(A), the assessee as well as Revenue are now in appeal before the Tribunal.

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14.

The Ld. counsel for the assessee, Shri M.V. Prasad, submitted that, the Ld. CIT(A) erred in estimating 25% profit on unaccounted cash receipts and unaccounted sales income, without appreciating the fact that the rate of profit adopted by the Ld. CIT(A) was not based on any contemporaneous data or comparable cases of a similar nature. The Ld. counsel for the assessee further submitted that, the A.O. made additions towards 100% of the cash receipts and unaccounted sales, even though the loose sheets found during the course of search clearly showed unaccounted expenditure. Further, the Managing Director of the assessee company had also stated that the unaccounted cash receipts received from the sale of flats had been spent in cash on various expenses relating to the project. Although there was clear evidence of incurring expenditure out of unaccounted cash receipts, the A.O. made additions towards 100% of the cash receipts without allowing any deduction towards expenditure. Although the Ld. CIT(A) accepted the arguments of the assessee, but the Ld. CIT(A) arbitrarily applied 25% profit, even though, in the assessee’s line of business, the rate of profit ranged from 10% to 15%. In this regard, he relied upon the decisions of the Hon’ble Andhra Pradesh High Court in the case of CIT v. Rajapushpa Properties and the Hon’ble Madhya

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Pradesh High Court in the case of CIT v. Sharda Real Estate Pvt. Ltd. The assessee also relied upon the decisions of ITAT, Hyderabad Bench, in the cases of Skill Promoters Private Limited vs. ACIT, Central Circle-2(3), Hyderabad, in ITA No.628/Hyd/2022 and others dated 31.10.2023 and M/s. Sri Sri Estates, Hyderabad vs. ACIT (ITA Nos. 2282 to 2285/Hyd/2018 dt.25.07.2018).

15.

The Ld. counsel for the assessee, further referring to the addition made by the A.O. and sustained by the Ld. CIT(A) towards unexplained cash credit of Rs. 50,80,000/-, submitted that, if at all the addition is sustained towards unexplained cash credit, then the benefit of telescoping shall be given against the addition sustained on the basis of estimated profit from unaccounted cash receipts from the sale of flats and unaccounted sales from the sale of villa. In case the estimated income from sales falls short of the unexplained cash credit, then the balance may be sustained.

16.

The Ld. CIT-DR, Ms. Seema Meena, on the other hand, supporting the order of the A.O., submitted that the assessee had admitted additional income towards cash receipts from the sale of flats, net of all expenditure, which was evident from the relevant statement recorded under Section 132(4) of the Act, from the

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Managing Director of the assessee company, K. Indrasena Reddy, wherein he had admitted additional income for the assessment years 2014-15 to 2017-18. The assessee had not filed any retraction statement either immediately after the date of search or before or during the course of assessment proceedings, and, in the absence of retraction along with relevant evidence, the claim of the assessee for estimation of reasonable profit could not be accepted. The Ld. CIT-DR further submitted that, the Ld. CIT(A), without appreciating the relevant facts, had simply estimated 25% profit on the total unaccounted cash receipts and unaccounted sales. The Ld. CIT(A) had not given any basis or brought on record any comparable cases of a similar nature. Therefore, the arbitrary estimation made by the Ld. CIT(A) could not be accepted. Accordingly, she submitted that the additions made by the A.O. towards unaccounted cash receipts and unaccounted sales income should be upheld.

17.

The Ld. CIT-DR further submitted that, the addition made by the A.O. towards unexplained cash credits related to unproved unsecured loans received from various parties should be upheld as the assessee had failed to file relevant evidence to prove the

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identity, creditworthiness and genuineness of the parties in respect of the unsecured loans. Therefore, the argument of the assessee that, if at all the addition was sustained towards unexplained cash credits, the benefit of telescoping should be given, was contrary to the facts and law, because what was added was the amount of unproved loans. Therefore, the estimated profit and cash flow available out of the estimated profit could not be telescoped against the unproved loans. Accordingly, she submitted that the addition made by the A.O. towards unsecured loans should be upheld.

18.

We have heard both parties, perused the material available on record and had gone through the orders of the authorities below. The facts borne out from the record show that, during the course of search in the case of the Giridhari Group, certain loose sheets were found and seized as per Annexure A/KIR/RES/1. Pages 158 and 159 of the said annexure contained details of the project ‘Villa Onyx’, including unaccounted cash receipts from the sale of villas. The incriminating material found during the course of search was confronted to the Managing Director of the assessee company, Sri K. Indrasena Reddy, and, in response to a specific question, in a

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statement recorded under Section 132(4) of the Act on 26.07.2018, he admitted the details of unaccounted cash receipts. Subsequently, he filed an affidavit dated 23.08.2018, admitting additional income of Rs. 1,88,05,973/- for the assessment years 2014-15 to 2017-18, including Rs. 17,34,440/- for A.Y. 2017-18. The A.O. made additions towards unaccounted cash receipts from the sale of flats and unaccounted income from the sale of Villa No. 23, on the ground that, although the assessee had admitted undisclosed income towards the sale of flats, but it had not disclosed the additional income while filing the return of income. The A.O. further noted that the assessee had also failed to explain the unaccounted cash receipts with relevant details, including the corresponding expenditure, if any, incurred out of the said cash receipts, so as to assess only the profit element embedded in those receipts or estimate a reasonable net profit on the total cash receipts.

19.

We have given our thoughtful consideration to the reasons given by the A.O. for making additions towards total cash receipts and unaccounted sales income, and also to the reasons given by the Ld. CIT(A) for estimating 25% profit on unaccounted sales

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income, in the light of various arguments advanced by the Ld. counsel for the assessee and the counter-arguments of the Ld. CIT(DR) representing the Revenue. Admittedly, during the course of search, incriminating material in the form of loose sheets was found, which contained various details of sales, including the extent of property, total consideration, amount received in cash, amount received by cheque and balance amount receivable. Further, the above loose sheets also contained various details of expenditure incurred out of unaccounted cash receipts. Once the document relied upon by the A.O. for making additions towards unaccounted cash receipts contains details of various expenditure incurred out of unaccounted cash receipts, in our considered view, making additions towards total cash receipts as the income of the assessee, while ignoring the expenditure incurred out of the said unaccounted cash receipts, is totally incorrect and contrary to the settled principles of taxation, as held by various courts, including the decision of the Hon’ble Gujarat High Court in the case of CIT v. President Industries, reported in [2002] 124 Taxman 654 (Gujarat), wherein it was held that the entire undisclosed sales cannot be treated as income of the assessee. The Hon’ble Court further held that sales represent the price received by the seller of

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the goods, for which the seller has also incurred costs. Therefore, the realization of excess consideration over the cost incurred should be assessed as profit or income. A similar view was taken by the Hon’ble Madhya Pradesh High Court in the case of CIT v. Balchand Ajit Kumar, reported in [2004] 135 Taxman 180 (Madhya Pradesh), wherein it was held that the net profit should be adopted as income. The Hon’ble Madhya Pradesh High Court, in the case of CIT v. Sharda Real Estate Pvt. Ltd., reported in 99 DTR 100 (Madhya Pradesh), considered an identical issue relating to the estimation of profit on unaccounted sales and, after considering the relevant facts, adopted 25% profit on the unaccounted turnover. The Co-ordinate Bench of the ITAT, Hyderabad, in the case of Skill Promoters v. ACIT, considered an identical issue of unaccounted cash receipts from the sale of flats and, after considering the relevant facts and evidence, estimated profit at 15% of the unaccounted cash receipts. The sum and substance of the ratio laid down by various High Courts and Tribunals is that the total unaccounted sales or cash receipts cannot be taxed, and what is to be taxed is only the profit element embedded in those receipts, after considering the nature of business and the evidence. The courts further held that the

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expenditure incurred out of unaccounted cash receipts should be considered. The courts also held that when sales are accepted, the corresponding purchases cannot be disputed. In other words, if we tax sales as income, the corresponding purchases or expenditure incurred to earn or realise the sales should be considered.

20.

In the present case, there is no dispute with regard to the fact that the material relied upon by the A.O. for the purpose of making an addition towards unaccounted cash receipts/sales also contains details of various expenditure incurred in cash out of unaccounted cash receipts for the purpose of business. Therefore, when the material contains both income and expenditure, selectively considering only one part of the material for the purpose of assessing income is incorrect. Therefore, in our considered view, when the material shows both income and expenditure, the only way to assess the income is by quantifying the net income on the basis of the material seized during the course of search. In case it is difficult to ascertain the correct amount of profit, only then a reasonable profit may be estimated by taking into account the nature of business and the judicial precedents on this issue, if any. Since the material relied upon by the A.O. clearly shows

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unaccounted income and expenditure, in our considered view, the learned CIT(A) has rightly resorted to estimation of profit.

21.

Having said so, let us consider whether the rate of profit adopted by the learned CIT(A) is reasonable, having regard to the nature of business of the assessee and the material available for the purpose of determination of income. The learned CIT(A) has adopted a profit rate of 25% on total unaccounted cash receipts/income on the basis of certain judicial precedents, including the decisions of the Hon’ble Madhya Pradesh High Court and the Hon’ble Andhra Pradesh High Court in the case of so-and- so, respectively. As we have already stated in the earlier part of this order, there is no hard and fast rule for estimation of profit, and it depends upon the facts of each case, including the nature of business and comparable cases of a similar nature. The assessee is engaged in the business of real estate development, including construction and sale of flats. In this line of business, the competition is very high, and therefore, adopting a uniform rate of profit without considering the relevant facts is incorrect. Since there are divergent views on the estimation of profit, particularly on the issue of adopting the rate of profit, in our

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considered view, having regard to the nature of business of the assessee and the material considered by the A.O. for the purpose of assessment of income, the profit rate of 25% adopted by the learned CIT(A) appears to be on the higher side. Therefore, taking into account the nature of business of the assessee and the evidence relied upon by the A.O. for the purpose of assessment, and also following the decision of the ITAT, Hyderabad, in the case of Skill Promoters Limited v. ACIT, supra, we deem it appropriate to estimate the profit at 15% on unaccounted cash receipts and unaccounted income from the sale of flats/apartments/villas. Accordingly, we modify the order of the learned CIT(A) to the extent of the rate of profit adopted and instead of estimating profit at 25% on total unaccounted cash receipts/sales income, we direct the A.O. to estimate profit at 15% on total unaccounted cash receipts and unaccounted sales income for all the assessment years, including for the assessment year 2017-18.

22.

Coming back to the additions made by the A.O. towards unexplained cash credits, being unsecured loans of Rs. 50,80,000/-, and sustained by the learned CIT(A). There is no dispute with regard to the fact that the assessee could not

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establish the identity of the loan creditors and also failed to prove the genuineness and creditworthiness of the parties. Therefore, in the absence of establishing the three ingredients provided under Section 68 of the Act, in our considered view, there is no error in the reasons given by the A.O. for making the addition towards unsecured loans as unexplained cash credits and the reasons given by the learned CIT(A) for sustaining the addition made by the A.O. To this extent, we are in full agreement with the reasons given by the A.O. and the learned CIT(A). However, the fact remains that, the assessee has made an alternative argument in light of the assessment of income on an estimation basis towards unaccounted cash receipts and unaccounted sales income. The assessee claimed that, if at all the unexplained or unproved loan is treated as income of the assessee, then the benefit of telescoping should be given out of the additional income assessed on the basis of estimation of profit on total unaccounted cash receipts and unaccounted sales income. In case the assessee has sufficient income out of the estimated profit on total unaccounted cash receipts and unaccounted sales income, the benefit of telescoping should be given against the additions made towards unaccounted, unexplained and unproved loans. In case the income assessed falls

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short of the addition made under Section 68 of the Act, then only the balance amount may be sustained.

23.

We find that, the A.O. has made additions towards unaccounted cash receipts from the sale of flats and villas and also made an addition towards unproved loans under Section 68 of the Act, as unexplained cash credits. It is a well-settled principle of law, as laid down in the decisions of various courts and Tribunals, that, in case any income is available to the assessee to explain the source of additions made on different counts, the benefit of telescoping should be given against such additions. In the present case, the income finally sustained on an estimation basis on total unaccounted cash receipts and unaccounted sales income is available to the assessee to explain the source of the unproved and unsecured loans. Since the assessee is not able to prove the unsecured loans with relevant details, in our considered view, the same should be assessed as undisclosed income of the assessee. Once the unsecured loans are treated as the assessee’s own income, which has been routed in the form of unsecured loans, the income available to the assessee out of the addition made towards estimated profit on unaccounted cash receipts, i.e., sales

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income, should be telescoped against the said addition. Therefore, we direct the A.O. to sustain the additions made towards unproved loans for all the assessment years, as the assessee has failed to prove the identity, genuineness of the transactions and creditworthiness of the parties. However, the A.O. is directed to allow the benefit of telescoping against the additions made under Section 68 of the Act, out of the income finally assessed on total unaccounted cash receipts, i.e., sales income from the sale of flats and villas. In case the income finally assessed on unaccounted cash receipts, i.e., sales income, is equal to or exceeds the additions made towards unproved loans under Section 68 of the Act, then the A.O. is directed to delete the entire additions made towards unexplained cash credits under Section 68 of the Act. In case, the income finally sustained on unaccounted cash receipts, i.e., sales income, falls short of the additions made under Section 68 of the Act, towards unproved unsecured loans, the A.O. is directed to sustain only the balance amount of the unproved loans under Section 68 of the Act, as unexplained cash credits.

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24.

In the result, the appeal filed by the assessee for A.Y. 2017- 18 is partly allowed and the appeal filed by the Revenue for A.Y. 2017-18 is dismissed.

ITA Nos.2086 to 2088, 2090 & 2091/Hyd/2026 and ITA No.2329/Hyd/2025

25.

The facts and issues involved in the remaining appeals filed by the assessee company for A.Ys. 2014-15, 2015-16, 2016-17, 2018-19 and 2019-20 and the appeal filed by the Revenue for the A.Y. 2018-19 are identical to the facts and issues which, we have considered in the cross appeals for the A.Y. 2017-18. But for the figures, the facts and issues are exactly identical. The reasons given by us in the preceding paragraphs i.e., 18 to 23 while deciding the cross appeals for the A.Y. 2017-18 shall mutatis mutandis apply to the remaining appeals, as well. Therefore, for the reasons given in the preceding paragraphs, we direct the A.O. to estimate 15% profit on unaccounted cash receipts and unaccounted income. Further, we sustain the addition made by the A.O. towards unsecured loans under Section 68 of the Act. However, we direct the A.O. to allow the benefit of telescoping out of the income finally assessed on estimation of profit on unaccounted cash receipts/unaccounted income. In case the

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income available to the assessee out of the estimated profit is equal or more than the addition towards unsecured loans under Section 68 of the Act, then we direct the A.O. to delete the addition made under Section 68 of the Act. In case the income finally assessed towards estimation of profit on unaccounted cash receipts/ unaccounted income falls short of the addition under Section 68 of the Act, then we direct the A.O. to sustain the balance amount of unsecured loans as unexplained cash credits under Section 68 of the Act. Accordingly, the appeals filed by the assessee for the A.Ys. 2014-15, 2015-16, 2016-17, 2018-19 and 2019-20 are partly allowed, and the appeal filed by the Revenue for the A.Y. 2018-19 is dismissed.

25.

To sum up, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed.

Order pronounced in the Open Court on 18th September, 2026.

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

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Hyderabad, dated 18.09.2026. TYNM/sps आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:- 1. निर्धाररती/The Assessee : GIRIDHARI CONSTRUCTIONS INDIA PRIVATE LIMITED HNO 121/A-1, JOURNALIST COLONY, JUBILEE HILLS, HYDERABAD-500033, TELANGANA 2. राजस्व/ The Revenue : 1. ACIT, CENTRAL CIRCLE-1(1), HYDERABAD-500004, TELANGANA. 2. DCIT, CENTRAL CIRCLE-1(1), HYDERABAD-500004, TELANGANA 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 TIRUPATI Digitally signed by TIRUPATI YAMINI NAGA YAMINI NAGA MALLESWARI Date: 2026.09.18 MALLESWARI 17:37:48 +05'30' Senior Private Secretary, ITAT, Hyderabad

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