ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(1) , HYDERABAD vs. S A BUILDERS AND DEVELOPERS , HYDERABAD

The appeals of the Revenue are dismissed

133A is not a search under section 132 as both\noperate in their respective fields and it is legally not\npermissible to equate both the actions as same.\n7. The learned CIT(A) should have appreciated that no\nvaluable or books of account belonging to the firm were seized\nfrom the residential premises of Syed Akthar (partner).\n8. The learned

KINETA GLOBAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

purchases which the assessee company had claimed to have made from M/s. Sauve Corporation India Pvt. Ltd, were bogus and, thus, the entire amount of bogus expenditure was treated by him as the income of the assessee company. The AO, based on his aforesaid observations after reducing the profit of Rs. 18,17,636/-, that the assessee company had claimed

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

133A, as the case may be, on or before the 31st day of March of a finacial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes of computing the period

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

133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes of computing the period

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

133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes of computing the period

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

133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes of computing the period

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:

133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes of computing the period

ANIRUDH VENKATA RAGI ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

purchase and at the time of sale, but even after three years from the date of sale of shares, in the year 2015, the shares were quoted in the Stock Exchange at Rs. 134.40 per share. It is, therefore, not a penny stock and the observations made by the learned Assessing Officer are not applicable to the facts

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

In the result, appeals of the assessee for the A

133A,\nas the case may be, on or before the 31st day of March of a\nfinacial year, in consequence of:\n\n(a) a search u/s 132 which is initiated; or\n(b) a search u/s 132 for which the last of authorization is\nexecuted or\n(c) a requisition made u/s 132A\n\nProvided also that

SRINIVAS SHAH RADRARAJU ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.957/Hyd/2019 (निर्धारण वर्ा/Assessment Year: 2014-15) Srinivas Shah Rudraraju Vs. Dcit, Circle-2(1) Hyderabad Hyderabad [Pan :Afcpr1979L] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 15/01/2025 घोर्णध की तधरीख/Date Of 05/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)]-2, Guntur, Pertaining To A.Y.2014-15. 2. The Brief Facts Of The Case Are That, The Assessee Is An Individual, Filed His Return Of Income For The A.Y.2014-15 On 31.03.2015, Admitting Total Income Of Rs.53,50,976/-. The Case Was Selected For Scrutiny Under Cass For The Reason ‘Suspicious Long Term Capital Gain On Shares’ & During The Course Of Assessment Proceedings, The Assessing Officer, Noticed That The 2 Srinivas Shah Rudra Raju

bogus in nature, which is taxable u/s 68 of the Act as unexplained cash credit, without carrying out further enquiries, either by furnishing relevant investigation report and statement of the persons to the assessee for his cross examination and rebuttal. Further, the Assessing Officer had also failed to carry out further enquiry to ascertain the true nature of transactions

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

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

133A,\nas the case may be, on or before the 31st day of March of a\nfinacial year, in consequence of:\n(a) a search u/s 132 which is initiated; or\n(b) a search u/s 132 for which the last of authorization is\nexecuted or\n(c) a requisition made u/s 132A\nProvided also that for the purposes

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

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

133A,\nas the case may be, on or before the 31st day of March of a\nfinacial year, in consequence of:\n(a) a search u/s 132 which is initiated; or\n(b) a search u/s 132 for which the last of authorization is\nexecuted or\n(c) a requisition made u/s 132A\nProvided also that for the purposes

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

In the result, appeals of the assessee for the A

133A,\nas the case may be, on or before the 31st day of March of a\nfinacial year, in consequence of:\n\n(a) a search u/s 132 which is initiated; or\n\n(b) a search u/s 132 for which the last of authorization is\nexecuted or\n\n(c) a requisition made u/s 132A\n\nProvided also that

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

133A,\nas the case may be, on or before the 31st day of March of a\nfinacial year, in consequence of:\n(a) a search u/s 132 which is initiated; or\n(b) a search u/s 132 for which the last of authorization is\nexecuted or\n(c) a requisition made u/s 132A\nProvided also that for the purposes

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

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

133A,\nas the case may be, on or before the 31st day of March of a\nfinacial year, in consequence of:\n\n(a) a search u/s 132 which is initiated; or\n(b) a search u/s 132 for which the last of authorization is\nexecuted or\n(c) a requisition made u/s 132A\n\nProvided also that

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

bogus.\n5. Any other legal and factual ground or grounds that may be\nurged at the time of hearing of the appeal.”\n\n3.\nThe brief facts of the case are that the assessee\ncompany filed the return of income for the A.Y 2020-21 on\n12.02.2021, admitting total Income of Rs.103,29,39,000/-. The\ncase was selected

SUBHASH KUMAR KEDIA,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.707/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Subhash Kumar Kedia Vs. Asstt. C. I. T. Hyderabad Central Circle 3(1) Pan:Afvpk8915Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No. 405/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Vs. Shri Bikash Kumar Asstt. C. I. T. Kedia Hyderabad Central Circle 3(1) Pan:Afapk8794E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Vamshi Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 29/10/2024 आदेश/Order Per Manjunatha, G. A.M These Two Appeals Filed By Different Assessees Are Directed Against The Separate, But Identical Orders Dated 31/01/2020 Of The Learned Cit (A)-11, Hyderabad Relating To Page 1 Of 33

section 45 of the Act and E that the addition of the same u/s 68 of the Act towards "unexplained credit is in contravention of the Provisions of the Income Tax Act, 1961. (b) Without prejudice to other grounds, the Ld. CIT(A) ought to have appreciated that the sale consideration of Rs. 4,78,75,867 / has been credited

BIKASH KUMAR KEDIA ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.707/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Subhash Kumar Kedia Vs. Asstt. C. I. T. Hyderabad Central Circle 3(1) Pan:Afvpk8915Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No. 405/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Vs. Shri Bikash Kumar Asstt. C. I. T. Kedia Hyderabad Central Circle 3(1) Pan:Afapk8794E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Vamshi Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 29/10/2024 आदेश/Order Per Manjunatha, G. A.M These Two Appeals Filed By Different Assessees Are Directed Against The Separate, But Identical Orders Dated 31/01/2020 Of The Learned Cit (A)-11, Hyderabad Relating To Page 1 Of 33

section 45 of the Act and E that the addition of the same u/s 68 of the Act towards "unexplained credit is in contravention of the Provisions of the Income Tax Act, 1961. (b) Without prejudice to other grounds, the Ld. CIT(A) ought to have appreciated that the sale consideration of Rs. 4,78,75,867 / has been credited