“Section 149(1)(b)(i)”

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

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order 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:

Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next ... finding at the time of granting the sanction as to why the reopening beyond 3 years is in accordance with the provisions of section 149(1)(b) of the Act. The alleged material which is the basis of reopening of the assessment does not reveal the fact that the income

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

In the result, all the six appeals i

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

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

circumstance of the case, sanction under\nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section 149(1)(b)(i)\nand Section 149(1)(b)(iii). Accordingly grant of sanction is liable\nto be declared as nullity and invalid and resultantly,\nimpugned ... Explanation (2) to section 148 of the\nI.T. Act as well as approval from the DGIT for complying the\nconditions laid down in section 149(1)(b) r.w.s. 151 of the I.T.\nAct because the notice u/s 148 of the Act was issued beyond\n3 years.\n10. The next

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

In the result, all the six appeals i

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

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

In the result, all the six appeals i

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

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

In the result, all the appeals of the assessee for the\nA

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... nchargeable to tax represented in the form of an asset and an\nentry/entries in the books of account as per the prpovisions\nof section 149(1)(b) of the Act. Therefore, the Assessing\nOfficer proposed to bring the case of the assessee in sub-\nclause(i) and sub-clause

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

Section 151 of the Act, has been granted\nmechanically and without satisfaction that how it fits under\nSection 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly\nPage 2 of 78\n\ngrant of sanction is liable to be declared as nullity and\ninvalid and resultantly, impugned notice ... nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section\n149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of\nsanction is liable to be declared as nullity and invalid and\nresultantly, impugned notice under Section

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

In the result, all the appeals of the assessee for the\nA

circumstance of the case, sanction under\nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section 149(1)(b)(i)\nand Section 149(1)(b)(ii). Accordingly grant of sanction is\nliable to be declared as nullity and invalid and resultantly ... nchargeable to tax represented in the form of an asset and an\nentry/entries in the books of account as per the prpovisions\nof section 149(1)(b) of the Act. Therefore, the Assessing\nOfficer proposed to bring the case of the assessee in sub-\nclause(i) and sub-clause

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

In the result, all the appeals of the assessee for the\nA

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly ... nchargeable to tax represented in the form of an asset and an\nentry/entries in the books of account as per the prpovisions\nof section 149(1)(b) of the Act. Therefore, the Assessing\nOfficer proposed to bring the case of the assessee in sub-\nclause(i) and sub-clause

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

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly

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

In the result, all the appeals of the assessee for the\nA

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly ... nchargeable to tax represented in the form of an asset and an\nentry/entries in the books of account as per the prpovisions\nof section 149(1)(b) of the Act. Therefore, the Assessing\nOfficer proposed to bring the case of the assessee in sub-\nclause(i) and sub-clause

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

Section 151 of the Act, has been granted\nmechanically and without satisfaction that how it fits under\nSection 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly\n\ngrant of sanction is liable to be declared as nullity and\ninvalid and resultantly, impugned notice under Section ... nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section\n149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of\nsanction is liable to be declared as nullity and invalid and\nresultantly, impugned notice under Section

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

Section 151 of the Act, has been granted\nmechanically and without satisfaction that how it fits under\nSection 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly\nPage 2 of 78\n\ngrant of sanction is liable to be declared as nullity and\ninvalid and resultantly, impugned notice ... nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section\n149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of\nsanction is liable to be declared as nullity and invalid and\nresultantly, impugned notice under Section

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee for the A

Section 151 of the Act, has been granted\nmechanically and without satisfaction that how it fits under\nSection 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly\nPage 2 of 78\n\ngrant of sanction is liable to be declared as nullity and\ninvalid and resultantly, impugned notice ... nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section\n149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of\nsanction is liable to be declared as nullity and invalid and\nresultantly, impugned notice under Section

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee for the A

Section 151 of the Act, has been granted\nmechanically and without satisfaction that how it fits under\nSection 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly\n\ngrant of sanction is liable to be declared as nullity and\ninvalid and resultantly, impugned notice under Section ... nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section\n149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of\nsanction is liable to be declared as nullity and invalid and\nresultantly, impugned notice under Section

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

Section 151 of the Act, has been granted\nmechanically and without satisfaction that how it fits under\nSection 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly\nPage 2 of 78\ngrant of sanction is liable to be declared as nullity and\ninvalid and resultantly, impugned notice under ... nSection 151 of the Act, has been granted mechanically and\nwithout satisfaction that how it fits under Section\n149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of\nsanction is liable to be declared as nullity and invalid and\nresultantly, impugned notice under Section

VISWANADH KANDULA,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, appeals of the assessee for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, 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 Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 ITA Nos 1084 to 1088 and 1207 of 2025 ACE Tyres ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned