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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

bogus. 5. Any other legal and factual ground or grounds that may be urged at the time of hearing of the appeal.” 3. The brief facts of the case are that the assessee company filed the return of income for the A.Y 2020-21 on 12.02.2021, admitting total Income of Rs.103,29,39,000/-. The case was selected for scrutiny

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

bogus. 5. Any other legal and factual ground or grounds that may be urged at the time of hearing of the appeal.” 3. The brief facts of the case are that the assessee company filed the return of income for the A.Y 2020-21 on 12.02.2021, admitting total Income of Rs.103,29,39,000/-. The case was selected for scrutiny

SUJIT AGARWAL ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2014-15 Shri Sujit Agarwal Vs. Dy. C. I. T. Hyderabad Central Circle 2(2) Pan:Aclpa3197P Hyderabad (Appellant) (Respondent) Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Ch V Gopinath, Cit(Dr) Date Of Hearing: 09/11/2023 Date Of Pronouncement: 22/11/2023 Order Per R.K. Panda, Vice-This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.01.2019 Of The Learned Cit (A)-12, Hyderabad Relating To A.Y.2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & The Managing Director Of The Company, M/S. Sawaria Pipes Pvt Ltd. He Filed His Original Return Of Income For The Impugned A.Y On 30.12.2014 Declaring Total Income Of Rs.20,13,600/- & Agricultural Income Of Rs.70,200/-. A Search & Seizure Operation U/S 132 Of The I.T. Act Was Conducted In The Case Of The Assessee On 12.01.2016. In Response To Notice U/S 153A Of The Act Issued On 6.9.2016, The Assessee Filed His Return

bogus LTCG. Rejecting the various explanations given by the assessee, the Assessing Officer rejected the claim of LTCG of Rs.6,89,76,599/- u/s 10(38) and made addition of Rs.7,97,38,105/- u/s 68 of the I.T. Act by observing as under: Page 3 of 17 ITA No 369 of 2019 Sujit Agarwal Page

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:

132A, in case of any other person on or after the 1st day of April, 2021, pertains or pertain to, or any information contained therein, 70relate to, the assessee; or (d) the Assessing Officer has received any information under the scheme notified under section 135A pertaining to income Page 48 of 74 ITA No 1894 of 2025 Exel Rubber Private

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

132A, in case of any other person on or after the 1st day of April, 2021, pertains or pertain to, or any information contained therein, 70relate to, the assessee; or (d) the Assessing Officer has received any information under the scheme notified under section 135A pertaining to income chargeable to tax escaping assessment for any assessment year in the case

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

132A, in case of any other person on or after the 1st day of April, 2021, pertains or pertain to, or any information contained therein, 70relate to, the assessee; or (d) the Assessing Officer has received any information under the scheme notified under section 135A pertaining to income chargeable to tax escaping assessment for any assessment year in the case

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

132A, in case of any other person on or after the 1st day of April, 2021, pertains or pertain to, or any information contained therein, 70relate to, the assessee; or (d) the Assessing Officer has received any information under the scheme notified under section 135A pertaining to income chargeable to tax escaping assessment for any assessment year in the case

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

ACIT, CENTRAL CIRCLE - 2(2), HYDERABAD vs. AMR INDIA LIMITED, HYDERABAD

In the result, Cross Objection No

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under Sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved. 13 ITA.Nos.534 & 535/Hyd./2024 & C.O.Nos.4 & 5/Hyd./2025 The question involved in the present

ACIT, CENTRAL CIRCLE - 2(2), HYDERABAD vs. AMR INDIA LIMITED, HYDERABAD

In the result, Cross Objection No

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under Sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved. 13 ITA.Nos.534 & 535/Hyd./2024 & C.O.Nos.4 & 5/Hyd./2025 The question involved in the present

KANISHK GUPTA ,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-3(1) , HYDERABAD

In the result, the appeal of assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita No.34/Hyd/2022 (निर्धारण वर्ा / Assessment Year: 2012-13)

purchase and sale of shares by the Appellant are bogus and aimed at taking benefit of exemption of long term capital gain. 10. That Ld CIT(A) erred in holding that the statements recorded on oath from different persons in respect of transaction by other beneficiaries without any reference to the appellant are evidence against the appellant 11. That

MAHESH REDDY ALTHURI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

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

bogus LTCG/.STCL. The relevant information is forwarded by the Directorate of Investigation, Kolkata. 1.6 Information received from the Directorate of Kolkata, wherein it is found that the directors / family members / promoters of M/s. AMR Jnia Limited have used penny stock to route their undisclosed income by booking Long Term Capital Gains through a company by name M/s. Twenty First Century

LATHA REDDY ALTHURI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

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

bogus LTCG/.STCL. The relevant information is forwarded by the Directorate of Investigation, Kolkata. 1.6 Information received from the Directorate of Kolkata, wherein it is found that the directors / family members / promoters of M/s. AMR Jnia Limited have used penny stock to route their undisclosed income by booking Long Term Capital Gains through a company by name M/s. Twenty First Century

RADHIKA REDDY ALTHURI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

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

bogus LTCG/.STCL. The relevant information is forwarded by the Directorate of Investigation, Kolkata. 1.6 Information received from the Directorate of Kolkata, wherein it is found that the directors / family members / promoters of M/s. AMR Jnia Limited have used penny stock to route their undisclosed income by booking Long Term Capital Gains through a company by name M/s. Twenty First Century

GIRISH REDDY ALTHURI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

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

bogus LTCG/.STCL. The relevant information is forwarded by the Directorate of Investigation, Kolkata. 1.6 Information received from the Directorate of Kolkata, wherein it is found that the directors / family members / promoters of M/s. AMR Jnia Limited have used penny stock to route their undisclosed income by booking Long Term Capital Gains through a company by name M/s. Twenty First Century

ACIT, CENTRAL CIRCLE-3(1), HYDERABAD vs. VIRENDER KUMAR GUPTA, HYDERABAD

In the result, the appeal of the assessee in ITA

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2012-13 Sri Jitender Kumar Gupta Vs. A.C.I.T Hyderabad Central Circle 3(1) Hyderabad (Appellant) (Respondent) Pan:Aappg6606B Assessment Year: 2013-14 Sri Virender Kumar Gupta Vs. A.C.I.T Hyderabad Central Circle 3(1) Hyderabad (Appellant) (Respondent) Pan:Aaspg1887D Assessee By: Shri K.C. Devdas, Ca Revenue By: Smt. T.H. Vijaya Lakshmi, Cit(Dr) Date Of Hearing: 25/09/2023 Date Of Pronouncement: 17/10/2023 Order Per Laliet Kumar, J.M These Are The Two Connected Appeals Filed By The Respective Assessees Are Directed Against The Common Order Dated 27.07.2022 Of The Learned Cit (A)-11, Hyderabad Relating To A.Ys. 2012-13 & 2013-14 Respectively. Since Identical Grounds Have Been Taken By The Assessees In Both These Appeals, Therefore, For Page 1 Of 23

purchased 1200 shares of M/s. Dignity Suppliers Ltd for Rs.400/- each on 13.10.2009. Subsequently, as per amalgamation schedule, 1200 shares of M/s. Dignity Suppliers Ltd were converted into 45600 shares of M/s. Twenty First Century Pvt Ltd. Out of 45600 shares of M/s. Twenty First Century Pvt Ltd, the assessee has sold 33500 shares on different dates relevant

JITENDER KUMAR GUPTA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, the appeal of the assessee in ITA

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2012-13 Sri Jitender Kumar Gupta Vs. A.C.I.T Hyderabad Central Circle 3(1) Hyderabad (Appellant) (Respondent) Pan:Aappg6606B Assessment Year: 2013-14 Sri Virender Kumar Gupta Vs. A.C.I.T Hyderabad Central Circle 3(1) Hyderabad (Appellant) (Respondent) Pan:Aaspg1887D Assessee By: Shri K.C. Devdas, Ca Revenue By: Smt. T.H. Vijaya Lakshmi, Cit(Dr) Date Of Hearing: 25/09/2023 Date Of Pronouncement: 17/10/2023 Order Per Laliet Kumar, J.M These Are The Two Connected Appeals Filed By The Respective Assessees Are Directed Against The Common Order Dated 27.07.2022 Of The Learned Cit (A)-11, Hyderabad Relating To A.Ys. 2012-13 & 2013-14 Respectively. Since Identical Grounds Have Been Taken By The Assessees In Both These Appeals, Therefore, For Page 1 Of 23

purchased 1200 shares of M/s. Dignity Suppliers Ltd for Rs.400/- each on 13.10.2009. Subsequently, as per amalgamation schedule, 1200 shares of M/s. Dignity Suppliers Ltd were converted into 45600 shares of M/s. Twenty First Century Pvt Ltd. Out of 45600 shares of M/s. Twenty First Century Pvt Ltd, the assessee has sold 33500 shares on different dates relevant

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

132A was executed during the financial year commencing on or after the first day of April, 2019. Sub-section (2) of Section 153B explains the execution of authorisation and as per which, the authorisation referred to in clause (a) and clause (b) of sub- section (1) shall be deemed to have been executed, in the case of search

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

132A was executed during the financial year commencing on or after the first day of April, 2019. Sub-section (2) of Section 153B explains the execution of authorisation and as per which, the authorisation referred to in clause (a) and clause (b) of sub- section (1) shall be deemed to have been executed, in the case of search