VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

ITA 1874/HYD/2025Status: DisposedITAT Hyderabad18 February 2026AY 2018-19Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MANJUNATHA G. (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the second notice issued under Section 148 was invalid as it was issued without complying with the mandatory procedures under Section 148A, especially after the initial reassessment proceedings were dropped. Consequently, the assessment order was quashed.

What were the facts?

Following a search and seizure operation, the assessee company was subjected to reassessment proceedings. The Assessing Officer issued a notice under Section 148, which was later dropped. Subsequently, a fresh notice under Section 148 was issued without adhering to the procedure laid down in Section 148A.

What were the issues?

The key issues were the validity of reassessment proceedings initiated by issuing a second notice under Section 148 after the first was dropped, and whether the procedure under Section 148A was followed.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 132,Section 148,Section 148A,Section 149,Section 151

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Income Tax Appellate Tribunal, Hyderabad ‘B’ Bench, Hyderabad

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.

Hearing: 19.01.2026

PER BENCH:

The above six appeals filed by the Assessee viz., Vilas Polymer Private Limited are directed against the separate Orders dated 29.10.2025 and 30.10.2025, of the learned CIT(A), Hyderabad-11, Hyderabad, arising from the assessment order passed u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961, pursuant to the search & seizure operations u/s 132 of the Act, dated 04/01/2023, in case of Excel Group

2 ITA.Nos.1870 to 1875/Hyd./2025 of Companies including the assessee for the A.Ys 2014-15 to 2019-20 respectively. Since common issues are raised in this group

The order continues below.

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