CDR PROJECTS PRIVATE LIMITED,SANGAREDDY vs. DCIT CIRCLE-1(1), HYDERABAD

आदेश / ORDER

PER VIJAY PAL RAO, VICE PRESIDENT:

This appeal is filed by the Assessee is directed against the Order dated 11.09.2025 of the Ld. CIT(A)-National Faceless Appeal Centre [in short "NFAC"], Delhi, for the Assessment Year 2013-14.

“The order of the learned Commissioner of Income Tax 1) (Appeals) is against the law, weight of evidence and probabilities of case. 2) The Learned CIT(A), NFAC erred in sustaining the reassessment proceedings for AY 2013-14 without appreciating that the notice under section 148, though bearing the date 31.03.2021, was in fact issued through the ITBA portal only on 01.04.2021, and having been issued after 31.03.2021 without adherence to the amended regime prescribed under section 148 read with section 148A, the notice is invalid and the consequential reassessment is void ab initio. 3) The Learned CIT(A), NFAC failed to appreciate that any notice issued on OR after 01.04.2021 mandatorily attracts compliance with section 148A, and non- compliance with such statutory pre-conditions vitiates the entire reassessment proceedings. 4) The Learned CIT(A), NFAC further erred in not holding that the reassessment notice for AY 2013-14, though dated 31.03.2021, was actually issued on 01.04.2021, i.e. beyond the permissible three-year limitation, and was sanctioned by the PCIT-1, Hyderabad instead of the competent authority under section 151(ii) (PCCIT/CCIT), thereby rendering the proceedings wholly without jurisdiction and void ab initio. 5) The learned CIT(A) ought to have appreciated that notice u/s 148 dt: 31.03.2021, issued on 01.04.2021, is issued beyond a period of six years in violation of provisions of section 149(1) of the IT Act, therefore, the learned Commissioner erred in not holding the assessment as null and void. 6) The appellant craves leave to add to, amend OR modify the above grounds of appeal either before OR at the time of hearing of the appeal, if it is considered necessary.”

ITO [2022] 449 ITR 517 (Del.HC) and submitted that an identical issue has been considered by the Honble Delhi High Court where the Assessing Officer claimed the notice u/sec.148 issued on 31.03.2021 as per the old provisions of sec.148 however, the said notice was found to be dispatched only on 01.04.2021 due to technical and procedural delays in ITBA system. The Hon’ble High Court has held that generation of notice on ITBA system does not satisfy the issue of requirement u/sec.149. Therefore, the notice issued u/sec.148 of the Act under the old provisions of sec.148 of the Act was held as invalid after 01.04.2021. He has then relied upon the decision of this Tribunal dated 24.09.2025 in the case of Sama Sangeeta Reddy vs. DCIT, CC-3(2), Hyderabad in ITA.No.680/Hyd./2025, dated 24.09.2025 and submitted that this Tribunal on identical facts has considered and decided this issue in favour of the assessee. The learned Authorised Representative of the Assessee has also relied upon the Judgment of Hon’ble jurisdictional Telangana High Court in the case of Kalyan Chillara vs. Dy. CIT [2024] 465 ITR 729 (Telangana-HC) and submitted that the notice issued by the Assessing Officer on or after 01.04.2021 are held as barred by limitation as the Assessing Officer was supposed to follow the provisions of sec.148A of the Act. Thus, the learned Authorised Representative of the Assessee has submitted that the notice issued by the Assessing Officer under old provisions of sec.148 is invalid and liable to be quashed.

7.1. Though the notice u/sec.148 bears the date 31.03.2021 and also digitally singed on the same date however, it was not sent to the assessee through email or any other mode of service but the same is claimed by the Assessing Officer as sent through ITBA system. The learned Authorised Representative of the Assessee has filed copy of the details of the notice issued for e-proceedings and at page no.133 of the paper book the copy of the relevant page of the ITBA is placed which reads as under:

7.2. Thus, even the ITBA Portal shows the notice u/sec.148 of the Act was issued on 01.04.2021. The Hon’ble Delhi High Court in the case of Suman Jeet Agarwal & Ors vs. ITO (supra) has held in Para nos.26.19 to 26.22 as under:

“26.19. It would also be relevant to note that the time taken by the ITBA e-mail software system on 31-3-2021, to dispatch the emails was not due to any software glitch. The time taken by the software system was as per the programming of the system, as admitted in the Compliance Affidavit. The programming to dispatch the Notices in a controlled manner and batch mode was a pre- existing fact and to the knowledge of the Department. The time taken in dispatch of the e-mail on 31-3-2021, was therefore as per the controls set in the ITBA system.

26.20. We are in respectful agreement with the law laid down by the various High Courts in Daujee Abhushan (supra), Santosh Krishna HUF(supra), Mohan Lal Santwani (supra), Advance Infradevelopers (P) Ltd. (supra) and Yuvraj v ITO (supra), that for determining when Notices were issued, the date and time of when the ITBA e-mail software system is triggered and the Notices leave the last ITBA server would be considered.

26.21. We therefore answer question no. (II) in affirmative and hold that dispatch as per section 13 of the Act of 2000, is a sine qua non and happens when the electronic mail message leaves the ITBAS servers.

26.22. We answer question no. (III) against the Department and hold that the time taken by the ITBAs e-mail software system in triggering the e-mail and transmitting the said e-mails from the ITBA servers is attributable to the Department and therefore for the e-mails dispatched on 1-4-2021 or thereafter, the Notices are held not to have been issued on 31-3-2021.

7.3. Thus, the Hon’ble Delhi High Court has held that dispatch as per sec.13 of Act of 2000 is sine qua non and happens only when the electronic mail message leaves the ITBAs servers. In the case in hand, the ITBA Portal clearly shows that the notice issued sent only on 01.04.2021 though the notice bears date 31.03.2021 and digitally signed but was not served on the assessee either by email or post or by courier service and it was just uploaded on the e-filing portal of the assessee. The Hon’ble Delhi High Court has further held in Para nos.28.1 to 28.5 as under:

“28.1. With respect to the Notices falling under the category D dated 31-3-2021 and digitally signed on 31-3-2021 it has been stated that, they were not served on the assessees either by e-mail or post or by courier services as they were just uploaded on the E- filing portals of the assessees. It is the case of the petitioners that no real time alert was received by the assessee and the Department has not disputed this fact.

28.2. The mode of service of electronic record, i.e., Notices in the present case is provided under section 282 of the Act of 1961 and Rule 127 of the Income Tax Rules. The mode of service of a notice, electronically, is prescribed in section 282 of the Act of 1961, it states that service maybe made by transmitting a copy in the form of electronic record as per chapter IV of the Act of 2000. It also states that the CBDT is empowered with the responsibility to make rules providing addresses for communication through electronic mail or electronic mail message. The CBDT vide Rule 127(b) of Income Tax Rules prescribed email addresses, as made available by the assessees, for communication transmitted electronically.

28.3. Thus, there is no dispute that the transmission of an electronic notice by placing an authenticated copy in the registered account of the assessee on the E-filing portal is not specifically prescribed in section 282 and Rule 127. Instead, it finds a mention in the CBDT Notification No. 4/2017 dated 3-4-2017. The said notification, provides that, the notices issued by any income tax authority will be visible to the assessee after logging in under E- Proceeding tab in the E-filing portal and that an e-mail may also be sent to the registered e-mail address of the assessee. It also mentions that a text message notifying a real time alert to the assessees may also be sent to the mobile number registered on the E-filing website.

28.4. The E-Proceedings, as per the Notification No.4/2017 is optional. The assessees have to register for the same and can also choose to opt out of it by notifying the Department.

28.5. It is unclear to us as to why e-mail based communication of notices is made optional in the Notification No. 4/2017, despite it being the statutorily prescribed mode of service through electronic transmission. Further, the ITBA portal itself is programmed in such a way that it triggers the e-mail software system when a notice is generated by the JAO and an authenticated copy of the same is thereafter also uploaded in the E-filing portal of the assessee, hence the Department cannot contend that it had done away with e-mailing of notices issued.

Most importantly, the Department has been consistently using this mode of e-mail based communication to transmit notices and no reason whatsoever has been provided to explain as to why these Notices were not e-mailed to the select few assessees falling under category D and was only uploaded on the Efiling portal. It is also unclear as to why the Notices though digitally signed on 31-3-2021 were never e-mailed to the assessees, because, as per the Compliance Affidavit, upon affixation of DSC by the JAO the e-mail software system of the ITBA portal would be automatically triggered.”

7.4. Thus, it was concluded in Para no.31.4 as under:

“31.4. Category D: The petitions challenging Notices falling under category D which were only uploaded in the E-filing portal of the assessees without any real time alert, are disposed of with the direction to the JAOs to determine the date and time when the assessees viewed the Notices in the E-filing portal, as recorded in the ITBA portal and conclude such date as the date of issuance in accordance with the law laid down in this judgment. If such date of issuance is determined to be on or after 1-4-2021, the Notices will be construed as issued under section 148A (b) of the Act of 1961 as per the Ashish Agarwal (supra) judgment.”

7.5. Accordingly, the notice which was found to be issued on 01.04.2021 at the most will be deemed as notice issued u/sec.148A(b) of the Act and therefore, the Assessing Officer was required to follow the procedure prescribed u/sec.148A of the Act. Even as per the directions of Hon'ble Supreme Court in the case of Union of India & Ors vs. Ashish Agarwal [2022] SCC OnLine (SC) 543 the Assessing Officer was required to follow the procedure as per new regime of re-assessment. However, in the case in hand the Assessing Officer has not followed the procedure prescribed u/sec.148A of the Act as well as directions of Hon'ble Supreme Court in the case of Ashish Agarwal (supra). Hence, the notice issued on 01.04.2021 under the old provisions of sec.148 is not valid. An identical issue has been considered by this Tribunal in the case of Sama Sangeeta Reddy, Hyderabad vs. DCIT, Central Circle-3(2), Hyderabad (supra) in Para nos.7 to 9 as under:

“7. We have heard both the parties, perused the material on record and had gone through the orders of the authorities below. We had also carefully considered the relevant notice issued by the Assessing Officer. Going by the screen-shot taken from ITBA portal and relevant case laws referred to by the Learned Counsel for the Assessee in support of their contentions, no dispute with regard to the fact that, notice issued under section 148 of the Act dated 31.03.2021 was issued on 01.04.2021 at 6.03 hours which is evident from email sent from HYDERABAD.ITO9.1@ incometax.gov.in to the email ID of the assessee krishna efiling @ gmail.com. Although, the learned Sr. AR for the Revenue refers to the digitally signed notice under section 148 of the Act which was on 31.03.2021 at 6.40 hours, in our considered view, the mere generation of notice on the ITBA portal and signing the same, is not sufficient for satisfying the test of issue and it is only when the notice has been dispatched, it would be declared to be issued. In the present case, there is no dispute with regard to the fact that, as per the email communication from the Department, the notice has been sent to the assessee on Thursday i.e., on 01.04.2021 at 6.03 hours and from the above, it is very clear that, notice under section 148 of the Act has been issued and served on the assessee on 01.04.2021. This legal principle is supported by the decision of Hon’ble High Court for the State of Telangana in the case of Kalyan Chillara vs., DCIT (supra) wherein in Para-26.9 of the Order it was clearly held that, “in order to determine when does "dispatch", i.e., the transmission of electronic record or the notices in the present case, from the Department occur, we may first note the precedence set by several High Courts in the context of Income Tax Business Application portal. Under section 13 of the Act of 2000, various High Courts have concluded that, the dispatch of an electronic record occurs when it enters a computer resource outside the control of the originator, i. e, when the Income Tax Business Application's e-mail system is triggered and the e-mail leaves the Income Tax Business Application servers”. In the present case, since the email from the Department i.e., Assessing Officer was triggered on Thursday i.e., on 01.04.2021 at 6.03 hours, in our considered view, it cannot be said that, notice under section 148 of the Act has been issued on 31.03.2021.

7.6. Thus, the Tribunal has considered the actual timing and date of the notice issued instead of the date mentioned on the notice and found that the notice was issued on 01.04.2021 and therefore, the procedure provided u/sec.148A of the Act as well as the amended provisions of sec.151 of the Act are applicable on such notice. We further note that the Hon’ble jurisdictional Telangana High Court in the case of Kalyan Chillara vs. Dy. CIT (supra) has decided the question framing in Para nos.23 and 24 as under:

“23. Further, the Division Bench, while dealing with the notices and reasons held as under, viz.,

.... .... ...

7.7. Accordingly, in the facts and circumstances of the case, when the notice u/sec.148 of the Act was issued only on 01.04.2021 as per the ITBA-Portal record which is not in dispute and the Assessing Officer has also not disputed the same except claiming that the notice was digitally signed on 31.03.2021 but no other evidence was filed regarding the issuance of notice other than sent through ITBA-Portal. The Assessing Officer has categorically stated in the report that apart from the ITBA-Portal this office is not in possession of any other evidence with regard to issuance of notice u/sec.148 of the Act. Therefore, the same is invalid being not issued by following the amended provisions of sec.148A of the Act.

“10. Coming back to the arguments of the Learned Counsel for the Assessee. Learned Counsel for the Assessee argued that, once notice issued under section 148 of the Act was held to be as per new regime of re-assessment under section 148 and 148A of the Income Tax Act, 1961, then, the approval for issue of such notice should be from the Pr. Chief Commissioner of Income Tax as

per section 151 of the Income Tax Act, 1961, whereas in the present case, the Assessing Officer has obtained approval from the Pr. Commissioner of Income Tax, Hyderabad-4, Hyderabad for issuance of notice under section 148 of the Act, which invalidates the said notice. We find that, as per the provisions of section 151 of the Act as amended from 01.04.2021, the Component Authority for sanction of issue of notice under section 148 at the Act is Pr. Chief Commissioner of Income Tax, if more than 3 years have elapsed from the end of the relevant assessment year. In the present case, there is no dispute with regard to the fact that, notice issued for the assessment year 2016-2017 on 01.04.2021 is beyond 3 years from the end of the relevant assessment year and consequently, the Assessing Officer ought to have taken sanction from the Pr. Chief Commissioner of Income Tax instead of Pr. Commissioner of Income Tax, Hyderabad-4, Hyderabad. Therefore, on this count also, notice issued under section 148 of the Income Tax Act, 1961 on 01.04.2021 is invalid and consequent assessment proceedings are bad in law and liable to be quashed. 11. The assessee has relied upon the decision of ITAT, Hyderabad Bench, Hyderabad in the case of Iqbal Ali Jaweed, Hyderabad vs., ITO [INT. TAXN]-1, Hyderabad (supra), in support of his contention. The Coordinate Bench of Hyderabad Tribunal on identical set of facts has held as under : “11. We have heard both the parties, perused the material on record and the orders of the authorities below. There is no dispute with regard to the fact that, reopening in the present case has been taken-up as per the amended provisions of sec.147, 148, 149, 151 of the Income Tax Act, 1961. As per the amended provisions of sec.148 of the Act which is evident from subsequent notices issued by the Assessing Officer u/sec.148 of the Act dated 27.07.2022 where the Assessing Officer in light of the decision of Hon’ble Supreme Court in the case of Union of India vs., Ashish Agarwal (supra), has considered the earlier notice issued u/sec.148, as fresh notice in light of provisions of sec.148A(d) of the Act. Therefore, it is necessary for us to examine the validity of notice issued by the Assessing Officer u/sec.148 of the Act, after obtaining prior approval of the Commissioner of Income Tax [International Taxation]-2, Mumbai accorded on 25.07.2022. Admittedly, the Assessing Officer issued notice u/sec.148 of the Act, after obtaining prior approval of the Commissioner of Income Tax [International Taxation]-2, Mumbai, dated 25.07.2022, but, as per the amended provisions of sec.151(ii) of the Act, the Competent Authority for granting sanction u/sec.151(ii) of the Act, in a case where the assessment has been reopened after 3 years from the end of the relevant assessment year is Pr. CCIT or Pr. Director General of Income Tax, but, not CIT as considered by the learned Assessing Officer. This legal principle is supported by the decision of ITAT, Hyderabad in the case of Raziulla Syed, Hyderabad vs., ITO [Intl. TAXN]-2, Hyderabad in ITA.No.986/Hyd./2024, dated 11.03.2025 for the assessment year 2017-2018, where under identical set of facts, the Tribunal by following certain judicial precedents including the decision of Hon’ble Bombay High Court in the case of Siemens Financial Services (P.) Ltd., vs., DCIT [2023] 457 ITR 647 (Bom.) held as under”

“7. We have heard the rival submissions of both the parties and perused the material available on record. There is no dispute between the parties that the assessee is a Non-Resident Indian. Admittedly, in the instant case, the assessment has been reopened u/sec.147 of the Act by issuance of notice u/sec.148 of the Act dated 23.04.2021 and by virtue of the order of Hon’ble Supreme Court in the case of Union of India vs. Ashish Agarwal reported in 2022-SC-Online-SC-543, re-assessment notice issued has been treated as notice issued u/sec.148A of the Act and after due procedure final notice u/sec.148 of the Act dated 30.07.2022 was issued. The assessee contends that any re-assessment notice issued u/sec.148 of the Act after 1st April, 2021 falls under New Scheme of re-assessment proceedings and as per sec.151, the approval of the Specified Authority as specified therein should be obtained. According to the assessee, under New Scheme of re-assessment proceedings, the Specified Authority u/sec. 151(ii) of the Act, in case an assessment is reopened after a period of three years from the end of the relevant assessment year, the Principal Chief Commissioner or Principal Director General are the Specified Authority(ies). Since in the present case, the Assessing Officer has issued notice u/sec.148 of the Act dated 30.07.2022 after approval from Principal Commissioner of Income Tax-1, Hyderabad, the said approval is not in accordance with provision of sec.151(ii) of the Act and consequently, the notice issued by the Assessing Officer and assessment order passed u/sec.147 r.w.s.144C(13) of the Act dated 02.03.2024 is illegal, void abinitio and liable to be quashed.

7.1. There is no dispute with regard to the fact that the Assessing Officer issued original notice u/sec.148 of the Act for the assessment year in question on 23.04.2021 and as per new scheme of re-assessment procedure, the same has been treated as notice issued u/sec.148A of the Act in light of decision of Hon’ble Supreme Court in the case of Union of India vs. Ashish Agarwal (supra) and finally re-assessment notice u/sec.148 was issued to the assessee on 30.07.2022 after approval from the Principal Commissioner of Income Tax- 1, Hyderabad dated 27.07.2022. As per the provisions of sec.151(ii) of the Act, if the reopening of the assessment is after three years from the end of the relevant assessment year, then the Specified Authority for grant of approval is Principal Chief Commissioner of Income Tax or Principal Director General of Income Tax and this legal principle is supported by the decision of Hon’ble Supreme Court in the case of Union of India vs. Rajeev Bansal [2024] 167 taxmann.com 70 (SC) wherein the Hon’ble Supreme Court has analysed the issue in light of decision of Hon’ble Supreme Court in the case of Union of India vs. Ashish Agarwal (supra), relevant Circulars/Notifications issued by CBDT and provisions of Taxation and Other Laws Amendment Act, 2021 [in short “TOLA”] and after considering relevant facts held that after 01.04.2021, the New Regime has specified different authorities for granting sanction u/sec.151(ii) of the Act and in case the assessment is reopened after three years from the end of the relevant assessment year, then the Specified Authority to grant sanction is the Principal Chief Commissioner of Income Tax or Principal Director General of Income Tax. In the present case, there is no dispute with regard to the fact that the Assessing Officer issued notice u/sec.148 of the Act dated 30.07.2022 with the prior approval of Principal Commissioner of Income Tax-1, Hyderabad accorded on 27.07.2022 vide Ref.F.No.Pr.CIT- 1/Hyd/147/2022-23. Therefore, in our considered view, notice issued by the Assessing Officer u/sec.148 of the Act dated 30.07.2022 with the approval of Principal Commissioner of Income Tax-1, Hyderabad dated 27.07.2022 is not in accordance with the provisions of sec.151(ii) of the Act and consequently, the re-assessment order passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Act is illegal, void abinitio and liable to be quashed.

7.2. The assessee has relied upon the decision of ITAT, Mumbai in the case of ACIT vs. Manish Financial ITA.No.5055/Mum./2024 wherein the Tribunal after considering the relevant provisions of law and also by following decision of Hon’ble Supreme Court in the case of Union of India vs., Rajeev Bansal (supra) held as under :

"In assessee's case from the perusal of para 3 of the notice issued under section 148 for AY 2016-17 we notice that the same is issued with the prior approval of Pr.CIT-19 Mumbai accorded on 29.07.2022 vide reference No.Pr.CIT-19/148/2022-23 and this fact is not contravened by the ld DR. For AY 2016-17, the period of three years have elapsed as of 31.03.2020 and the notice is issued beyond three years on 30.07.2022. Therefore as per the decision of the Hon'ble Supreme Court, the approval should have been obtained under the amended provisions of section 151(ii) of the Act i.e. the approval should have been obtained from the Principal Chief Commissioner whereas the approval has been obtained from Pr. CIT as stated in the notice under section 148 itself. Therefore we see merit in the contention of the assessee that the notice under section 148 for AY 2016-17 is issued without obtaining the prior approval from the appropriate authority. Accordingly we hold that the notice under section 148 is invalid and the consequent assessment under section 147 is liable to be quashed."

7.3. The assessee also relied upon the decision of ITAT, Mumbai Bench in the case of Manish Jagdish Joshi vs. CIT ITA.No.1617/Mum./2024 and the Mumbai Bench of the Tribunal by following the decision of Hon’ble Bombay High Court in the case of Siemens Financial Services (P.) Ltd., vs. DCIT [2023] 457 ITR 647 (Bom.) held as under :

“We find that while considering the similar issue and similar submissions the Hon'ble Jurisdictional High Court in Siemens Financial Services (P.) Ltd. v/s DCIT, (2023) 457 ITR 647 (Bom.) held that TOLA would not affect the scope of section 151 and sanction of Specified Authority was to be obtained in accordance with the law existing when the sanction was obtained. It was further held that where the Assessing Officer issued a reopening notice beyond the period of three years, approval was required to be taken as per provisions of amended section 151 from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. Therefore, respectfully following the aforesaid decision of the Hon'ble Jurisdictional High Court we find no merits in the reliance placed by the Revenue on the provisions of TOLA. As, in the present case, the period of three years has elapsed from the end of the relevant assessment year and the order dated 23/05/2022 was passed under section 148A(d) of the Act after obtaining the approval of the Principal CIT-1, Mumbai vide letter dated 15/07/2022, we are of the considered view that the Revenue has not followed the mandatory provisions of the Act while initiating the reassessment proceedings and sanction of the Specified Authority is not in conformity with the law prevalent at the time of grant of sanction." 7.4. In this view of the matter and by respectfully following the decision of Hon’ble Supreme Court in the case of Union of India vs. Rajeev Bansal (supra) and also the decisions of ITAT, Mumbai Benches, Mumbai in the cases of ACIT vs. Manish Financial and Manish Jagdish Joshi vs. CIT (supra), we are of the considered view that the notice issued by the Assessing Officer u/sec.148 of the Act dated 30.07.2022 by obtaining prior approval from the Principal Commissioner of Income Tax-1, Hyderabad dated 27.07.2022 and consequential final assessment order dated 02.03.2024 passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Act is illegal, void abinitio and thus, we quash the final assessment order dated 27.07.2022 passed by the Assessing Officer.” 12. In this view of the matter and considering the facts and circumstances of the present case and also by following the decision of ITAT, Hyderabad Bench, Hyderabad in the case of Raziulla Syed, Hyderabad vs., ITO [Int. TAXN]-2, Hyderabad (supra), we are of the considered view that the notice issued u/sec.148 of the Act dated 27.07.2022 by obtaining prior approval from the Commissioner of Income Tax [International Taxation]-2, Mumbai dated 25.07.2022 is not in accordance with sec.151(ii) of the Income Tax Act, 1961 as applicable from 01.04.2021 onwards. Therefore, we quash the notice issued u/sec.148 of the Act dated 01.04.2021 and 27.07.2022 and consequent Final Assessment Order dated 13.03.2024 passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Income Tax Act, 1961. Accordingly, the grounds raised by the assessee for the assessment year 2016-2017 are allowed”.

8.1. Accordingly, the notice issued by the Assessing Officer u/sec.148 of the Act without valid approval from the Competent Authority as per the provisions of sec.151(ii) of the Act at the time of issuing the notice on 01.04.2021 is invalid and liable to be quashed. We Order accordingly.

Order pronounced in the open court on this the 12th day of June, 2026.

Sd/- Sd/- MANJUNATHA G. VIJAY PAL RAO ACCOUNTANT MEMBER VICE PRESIDENT Hyderabad, Date 12th June, 2026 VBP Copy to : CDR PROJECTS PRIVATE LIMITED, 10-4/7 ROAD [1 NO.7 ,VIDYANAGAR COLONY POTHIREDDYPALLY, SANGAREDDY-502295, TELANGANA. 2 DCIT CIRCLE-1(1), IT TOWERS, AC GUARDS, KHAIRATABAD, HYDERABAD-500004, TELANGANA 3 THE Pr. CIT, Hyderabad. 4 THE D.R., ITAT, A-Bench, HYDERABAD. 5 GUARD FILE TRUE COPY VADREVU Digitally signed by VADREVU PRASADA PRASADA RAO Date: 2026.06.12 ASSISTANT REGISTRAR / RAO I.T.A.T., HYDERABAD 11:37:00 +05'30'