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

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.”\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 for scrutiny

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

147 of the Act. 3. Thereafter, the AO issued a “Show cause notice” (SCN) under section 148A(b) of the Act, dated 24/03/2022, calling upon the assessee company to put forth its objections till 31/03/2022. Order under clause (d) of section 148A of the Act, dated 24/01/2022, was passed by the AO, which was followed by a notice issued under

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED , HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

147 of the Income Tax Act, 1961 (“the Act”) for the reasons recorded, as per which, the information available with the department reveals that during the F.Y.2013-14, relevant to A.Y.2014-15, the assessee had made purchases to the tune of Rs.2,20,81,719/- from M/s Jagannath Agro Ltd. and such financial transaction has been reported to be bogus in nature

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED, HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

147 of the Income Tax Act, 1961 (“the Act”) for the reasons recorded, as per which, the information available with the department reveals that during the F.Y.2013-14, relevant to A.Y.2014-15, the assessee had made purchases to the tune of Rs.2,20,81,719/- from M/s Jagannath Agro Ltd. and such financial transaction has been reported to be bogus in nature

AMARAVATI,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation

AMARAVATI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation

AMARAVATI ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation

AMARAVATI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report of the Investigation

MEENA JEWELS AND PEARLS,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

bogus purchases based on information from a search and seizure operation. The assessee argued that the reopening was invalid as it was beyond 4 years and based on a change of opinion, and that all necessary documentation for purchases had been provided.", "held": "The Tribunal held that the reopening of assessment after 4 years was not valid as there

VITHALDAS AND COMPANY (SICNE DISSOLVE), HYD,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD, HYDERABAD

Appeals are partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under

VITHALDAS AND COMPANY (SICNE DISSOLVE), HYD,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD, HYDERABAD

Appeals are partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under

VITHALDAS AND COMPANY (SICNE DISSOLVE), HYD,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD, HYDERABAD

Appeals are partly allowed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED, HYDERABAD

In the result, all the three appeals filed by the Revenue for\nthe A

147 of the Income Tax Act, 1961\n(\"the Act\") for the reasons recorded, as per which, the\ninformation available with the department reveals that during\n3\nITA No.980/Hyd/2024,1079/Hyd/2024 & 1080/Hyd/2024\nRohini Minerals Private Limited\nthe F.Y.2013-14, relevant to A.Y.2014-15, the assessee had\nmade purchases to the tune of Rs.2,20,81,719/- from M/s\nJagannath Agro Ltd. and such

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

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

SPR INFRASTRUCTURE INDIA LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-3(2), HYDERABAD, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu(Through Virtual Hearing)

147 clearly refer to the income which is chargeable to tax but has "escaped assessment" and the ITO's jurisdiction under the section is confined only to such income which has escaped assessment. It does not extend to reconsidering generally the concluded earlier assessment. Claims which have been disallowed in the original assessment proceeding cannot be permitted

VITHALDAS AND COMPANY ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1, HYDERABAD

Appeal is partly allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

Section 148 and 147 mechanism culminating in the impugned bogus purchases disallowances affirmed upto the CIT(A)’s order(s) under