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

ITA 1884/HYD/2025Status: DisposedITAT Hyderabad18 February 2026AY 2021-22Bench: 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 notice issued under Section 148 was bad in law as the AO failed to fulfill the prescribed conditions for reopening the assessment, particularly when relying on material from another person's search. Consequently, the assessment order was quashed.

What were the facts?

During a search operation, unaccounted income was detected in the assessee's group, with a portion attributed to the assessee. The Assessing Officer (AO) made additions based on material found during a search of a third party's premises, not the assessee's direct search.

What were the issues?

Whether the assessment order passed under Section 147/148 is void ab initio due to non-compliance with the conditions for reopening, especially when based on material from a third-party search?

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 132,Section 148A

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Cases cited in this judgment(3)Show list

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

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

Hearing: 19/01/2026

Per MANJUNATHA, G. A.M. These two appeals are filed by the assessee and are directed against the two separate orders passed by the Learned Commissioner of Income Tax (Appeals)-11, Hyderabad, both dated 31/10/2025, for the Asst. Years 2020-21 & 2021-22 respectively. Since identical issues are involved in these two appeals, for the sake of convenience, these two appeals were heard together and are being disposed off, by this common consolidated order.

ITA Nos 1876 an

The order continues below.

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