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

purchase or acquisition of any asset. Therefore, the business transactions of sale of scrap or commission income etc, as well as the expenditure incurred in relation to the business activity would not constitute of an asset in terms of section 149(1)(b) of the Act. It is also a matter of fact and record that these transactions as found

KAVERI POLYMERS,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

c) of the Act. In conclusion, this Court is of the view that there is no illegality in the order of the learned ITAT in the present case. In all four appeals, the question of law involved is thus answered in favour of the assessee. The revenue's appeals are therefore dismissed.” 7. The ld.AR had further submitted that

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE-1(3),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

c) of the Act. In conclusion, this Court is of the view that there is no illegality in the order of the learned ITAT in the present case. In all four appeals, the question of law involved is thus answered in favour of the assessee. The revenue's appeals are therefore dismissed.” 9. The ld.AR had further submitted that

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

c) of the Act. In conclusion, this Court is of the view that there is no illegality in the order of the learned ITAT in the present case. In all four appeals, the question of law involved is thus answered in favour of the assessee. The revenue's appeals are therefore dismissed.” 9. The ld.AR had further submitted that

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

13 and Question No.21 as under: Q.13. Please refer to the Q.No.60 of your statement recorded at your residence during the course of Search and Seizure wis 132 of the 1.T. Act, 1961 which is reproduced below. Q.60. I am showing you excel workbooks named "CASH ACE 21-22", "CASH EXEL 20-21", "CASH EXEL

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

13 and Question No.21 as under: Q.13. Please refer to the Q.No.60 of your statement recorded at your residence during the course of Search and Seizure wis 132 of the 1.T. Act, 1961 which is reproduced below. Q.60. I am showing you excel workbooks named "CASH ACE 21-22", "CASH EXEL 20-21", "CASH EXEL

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

13 and Question No.21 as under: Q.13. Please refer to the Q.No.60 of your statement recorded at your residence during the course of Search and Seizure wis 132 of the 1.T. Act, 1961 which is reproduced below. Q.60. I am showing you excel workbooks named "CASH ACE 21-22", "CASH EXEL 20-21", "CASH EXEL

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:

13 and Question No.21 as under: Q.13. Please refer to the Q.No.60 of your statement recorded at your residence during the course of Search and Seizure wis 132 of the 1.T. Act, 1961 which is reproduced below. Q.60. I am showing you excel workbooks named "CASH ACE 21-22", "CASH EXEL 20-21", "CASH EXEL

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

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

13 nos labour charg\nfencing poles remoung work-labour charges\ndaily labour-water curing 27/4 to 3/5/2013\nwind power roof labour charges-swamy\n(machines cleaning labour charges-27-4-2013\n10,040 Repairs & Maintenance Factory\n20,00,000 Commissions & Other Miscellaneous Business Expemes\n1.00,000 Commissions & Other Mocellaneous Rusiness Expenses\nContra Entries & Other Advances\n550 Hamal Payments

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

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

13 and\nQuestion No.21 as under:\nQ.13 Please refer to the Q.No.60 of your statement recorded at your residence during the\ncourse of Search and Seizure u/s 132 of the I.T. Act, 1961 which is reproduced below.\nQ.60 I am showing you excel workbooks named \"CASH ACE 21-22\", \"CASH\nEXEL 20-21\", \"CASH EXEL 21-22\" and \"CASH

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

13 nos labour charg\n1,600\nCommissions & Other Miscellaneous Business Expenses\n04-05-2013 Cash\nfencing poles remoung work-labour charges\n3,800\nRepairs & Maintenance Factory\n04-05-2013 Cash\ndaily labour-water curing 27/4 to 3/5/2013\n4,075\nCommissions & Other Miscellaneous Business Expenses\n08-05-2013 Cash\nwind power roof labour charges-swamy\n4,400\nRepairs & Maintenance - Factory

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

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

13 nos labour charg\nfencing poles remoung work-labour charges\ndaily labour-water curing 27/4 to 3/5/2013\nwind power roof labour charges-swamy\n(machines cleaning labour charges-27-4-2013\n\n800 Commissons & Other Mocefaneous Buuness Expenses\n2,200 Commissions & Other Miscellaneous Bussen Exponen\n3,000 Commissions & Other Miscelaneous Business Expemes\n$150 Commissions & Other Mistellaneous Busness Expenses

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

In the result, appeals of the assessee for the A

section\n149(1)(b) of the Act, empowers an authority to issue\nnotice u/s 148 of the Act, if the alleged income is represented\nby any asset or expenditure. It is apparent on the face of the\nshow-cause notice( in brief "SCN"), that assessing officer is\nnot certain, as to whether in assessee`s case, the alleged\nescaped income

RAM GOPAL,HYDERABAD vs. ITO WARD-8(2), HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

Sections 68 and 69C of the Income Tax Act. The entire purchases shown on the basis of fictitious invoices have been debited in the trading account since the transaction has been found to be bogus. The Tribunal having once come to a categorical finding that the amount of Rs. 2,92,93,288/- represented alleged purchases from bogus suppliers

RAM GOPAL,HYDERABAD vs. ITO, WARD-8(2), HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

Sections 68 and 69C of the Income Tax Act. The entire purchases shown on the basis of fictitious invoices have been debited in the trading account since the transaction has been found to be bogus. The Tribunal having once come to a categorical finding that the amount of Rs. 2,92,93,288/- represented alleged purchases from bogus suppliers

RAM GOPAL,HYDERABAD vs. ITO WARD-8(2), HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Laliet Kumar

Sections 68 and 69C of the Income Tax Act. The entire purchases shown on the basis of fictitious invoices have been debited in the trading account since the transaction has been found to be bogus. The Tribunal having once come to a categorical finding that the amount of Rs. 2,92,93,288/- represented alleged purchases from bogus suppliers

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

In the result, appeals of the assessee for the A

section 148 of the\nIncome Tax Act, 1961\nImproper many is\ncovered w/1149(1)(b).\nIsame of motive of/5148\nis ayyun.\n\nDate: 6/10/23\n\nPage 52 of 78\n\n28.\nThough there is a recommendation by the Pr. CIT,\nhowever, the sanction/approval granted by the DG reveals that it\nhas concurred with the proposal that the impugned matter\ncovered

M/S. COUNTRY CLUB INDIA LTD.,,HYDERABAD vs. ACIT, CIRCLE-1(2), HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

purchase of items such as vegetables, fruits, dairy, poultry, milk and other sundry expenses from the small vendors who do not have any bank account and hence could not be paid in cheques / through banking channel. Hence, disallowance u/s. 40A(3) is not called for. 4. That the assessee company is running hotel business and the company is having

DY.CIT, CIR-1(2), HYDERABAD vs. M/S CUNTRY CLUB (I) LIMITED,, HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

purchase of items such as vegetables, fruits, dairy, poultry, milk and other sundry expenses from the small vendors who do not have any bank account and hence could not be paid in cheques / through banking channel. Hence, disallowance u/s. 40A(3) is not called for. 4. That the assessee company is running hotel business and the company is having