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

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

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2. 2. Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause

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

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2. 2. Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause

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

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2. 2. Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause

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:

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2.2 Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause (i) of explanation

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

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

purchase\ntransactions and cash received on sale of lands,\netc to the tune of Rs. 6,08,84,018/- for the AY:\n2015-16.\n2.\nFurther, as the AO upon considering the\nfacts and circumstances of the case decided that\nthe present case is 'a fit case' for issuance of\nnotice u/s 148 of I.T.Act, as per clause

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

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

purchase\ntransactions and cash received on sale of lands,\netc to the tune of Rs. 6,08,84,018/- for the AY:\n2015-16.\n2.\nFurther, as the AO upon considering the\nfacts and circumstances of the case decided that\nthe present case is 'a fit case' for issuance of\nnotice u/s 148 of I.T.Act, as per clause

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

purchase\ntransactions and cash received on sale of lands,\netc to the tune of Rs. 6,08,84,018/- for the AY:\n2015-16.\n2.\nFurther, as the AO upon considering the\nfacts and circumstances of the case decided that\nthe present case is 'a fit case' for issuance of\nnotice u/s 148 of I.T.Act, as per 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

purchase\ntransactions and cash received on sale of lands,\netc to the tune of Rs. 6,08,84,018/- for the AY:\n2015-16.\n2.\nFurther, as the AO upon considering the\nfacts and circumstances of the case decided that\nthe present case is 'a fit case' for issuance of\nnotice u/s 148 of I.T.Act, as per clause

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

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

In the result, appeals of the assessee for the A

148A(d) and /\nor issuance of notice\nunder 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

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

148A(d) dated 28.07.2022 was passed, as a consequence, notice u/s 148 of the Act dated 29.07.2022 was issued and served on the assessee. In response to the notice u/s 148 of the Act, the assessee had filed return of income on 25.08.2022, declaring total income at Rs.9,08,72,987/-. 4. During the course of assessment proceedings, the Assessing

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

148A(d) dated 28.07.2022 was passed, as a consequence, notice u/s 148 of the Act dated 29.07.2022 was issued and served on the assessee. In response to the notice u/s 148 of the Act, the assessee had filed return of income on 25.08.2022, declaring total income at Rs.9,08,72,987/-. 4. During the course of assessment proceedings, the Assessing

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

148A(d) dated\n28.07.2022 was passed, as a consequence, notice u/s 148 of\nthe Act dated 29.07.2022 was issued and served on the\nassessee. In response to the notice u/s 148 of the Act, the\nassessee had filed return of income on 25.08.2022, declaring\ntotal income at Rs.9,08,72,987/-.\n4. During the course of assessment proceedings, the\nAssessing

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

1. On the facts and circumstance of the case, Learned CIT(A)\nerred in passing the order both on law and facts.\n2. On the facts and circumstance of the case, the Learned\nCIT(A) is not justified in dismissing the ground that the issue\nof notice U/s 148 by the Assessing Officer is without\nJurisdiction.\n3. On the facts

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

1. On the facts and circumstance of the case, Learned CIT(A)\nerred in passing the order both on law and facts.\n2. On the facts and circumstance of the case, the Learned\nCIT(A) is not justified in dismissing the ground that the issue\nof notice U/s 148 by the Assessing Officer is without\nJurisdiction.\n3. On the facts

MUMTAZ ALI MOHD,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(1), HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आ.अपी.सं /Ita No.1260/Hyd/2024 (िनधा"रण वष"/Assessment Year:2014-15) Mumtaz Ali Mohd, Vs. Income Tax Officer, Hyderabad. Ward-8(1), Pan: Abppm6593E Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By: Shri K. Vonoth Kannan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Date Of 09/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 09/01/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 12/05/2023 For The Assessment Year (Ay) 2014-15. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

1), Hyderabad issued notice u/s 148A(b); order u/s 148A(d) and notice u/s 148 and he has no jurisdiction to issue such notice. 3) The order of assessment is invalid as the notice was not issued within the time and was issued by an officer who has no jurisdiction to do so.” 3. As the assessee by raising