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

ITA 1894/HYD/2025Status: DisposedITAT Hyderabad18 February 2026AY 2014-15Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha G. (Accountant Member)49 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the notice under Section 148 was issued without fulfilling the mandatory conditions, and the approval granted was mechanical without application of mind.

What were the facts?

A search operation uncovered unaccounted transactions in software, leading to the admission of undisclosed income by the assessee. The Assessing Officer issued a notice under Section 148 for reassessment, making additions based on these transactions.

What were the issues?

The primary issues were the validity of the reassessment proceedings initiated under Section 148 and whether the conditions for issuing such notice, especially after three years, were met. The mechanical approval by the prescribed authority was also a key point.

Which sections of the Income-tax Act were involved?

Section 132,Section 148,Section 147,Section 143(3),Section 149(1)(b),Section 151,Section 69A

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

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

Hearing: 20/01/2026

Per MANJUNATHA, G. A.M. This appeal is filed by the assessee is directed against the order passed by the Learned Commissioner of Income Tax (Appeals)-11 Hyderabad, dated 11/10/2025 for the A.Y 2014-15. 2. The assessee has raised the following grounds of appeal:

ITA No 1894 of 2025 Exel Rubber Private Ltd

3.

The brief facts of the case are that the assessee company filed its return of income for the Asst. Year 2014-15 on 30.09.2014 admitting total Income of Rs.37,48,96,236/-. A Search and S

The order continues below.

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