EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

ITA 1106/HYD/2025Status: DisposedITAT Hyderabad24 September 2025AY 2015-1666 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer failed to fulfill the conditions laid down under Section 149(1)(b) and Section 151 of the Income Tax Act for reopening the assessment. The sanction for reopening was granted mechanically without proper satisfaction.

What were the facts?

A search and seizure operation was conducted on the assessee company and its group concerns, leading to the discovery of unaccounted cash receipts. Based on this, the Assessing Officer reopened assessments for multiple years, including AY 2015-16, by issuing notices under Section 148.

What were the issues?

The key issues were the validity of the notice issued under Section 148 and the proper compliance with the conditions laid down in Sections 149 and 151 for reopening assessments after a search operation.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 149,Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad DB-B‘Bench, Hyderabad

Before: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
For Respondent: Dr. Sachin Kumar, Sr. AR
Hearing: 03/09/2025

Per Bench: These five appeals by the assessee are directed against the separate orders dated 20/06/2025, 21/06/2025, 23/06/2025, 25/06/2025 and 15/07/2025 respectively of the learned CIT (A)-11, Hyderabad for the A.Ys.2015-16 to 2019-20 arising from the assessment order passed u/s 143(3) r.w.s. 147 of the Act, pursuant to the search & seizure operations dated 04/01/2023 in case of Exel Group of Companies including the assessee for the A.Ys 2014-15 to 2019-20 respectively. Since common issued are raised in these group of five a

The order continues below.

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