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

ITA 1109/HYD/2025Status: DisposedITAT Hyderabad24 September 2025AY 2018-1966 pages
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What did the Tribunal hold?

The Tribunal held that the notices issued under Section 148 were bad in law as the conditions of Section 149(1)(b) were not fulfilled and the sanction under Section 151 was granted mechanically without proper application of mind. Consequently, the assessment orders passed pursuant to these notices were also vitiated.

What were the facts?

Following a search and seizure operation, the Assessing Officer (AO) issued notices under Section 148 of the Income Tax Act to the assessee for multiple assessment years. The assessee challenged these notices, arguing they were issued without jurisdiction and were bad in law due to non-compliance with Sections 148 and 149 of the Act, and that the approval under Section 151 was granted mechanically.

What were the issues?

The key issues were the validity of the notices issued under Section 148, the compliance with the conditions laid down in Section 149, and the proper application of mind by the sanctioning authority under Section 151.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(1)Show list

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  • 237 Taxmann.com 378
    237 Taxmann.com 378
    7 citing

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

The order continues below.

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