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

bogus purchases. Hon’ble Gujarat High Court in the case of Krishna Textiles Vs. CIT [2008] 174 Taxman 372 [2009] held that, the onus was on the revenue to prove that the income belongs to the assessee. The AO in this case did not doubt the sales, stock record maintained by the assessee. In the absence of any contrary finding

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

bogus purchases. Hon'ble\nGujarat High Court in the case of Krishna Textiles Vs. CIT\n[2008] 174 Taxman 372 [2009] held that, the onus was on the\nrevenue to prove that the income belongs to the assessee. The\nAO in this case did not doubt the sales, stock record maintained\nby the assessee. In the absence of any contrary

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, 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

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

36,659\n2,51,76,51,3151240661\n12\nसवाल\n6/1/2025\nAs stated earlier, these unaccounted cash transactions as recorded above contain details of\ncash generated from sale of scrap, purchase adjustments/accommodations, sale of raw\nmaterials, sale of immovable property, interest received on loans advanced, repayment of\nsuch loans advanced by M/s Exel Group and its Management in their individual capacity

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

36,659\n2,51,76,51,3151240661\n\nए. टी. वी. कमार, भारा से.\nKA TV. KUMAR. IR S.\n\n12\n\n6/1/2025\n\nAs stated earlier, these unaccounted cash transactions as recorded above contain details of\ncash generated from sale of scrap, purchase adjustments/accommodations, sale of raw\nmaterials, sale of immovable property, interest received on loans advanced, repayment

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

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

36,659\n2,51,76,51,3151240661\nArivkumar\n06/01/22\nए. टी. वी. कमार, भारा से.\nKA TV. KUMAR. IR S.\n12\n6/1/2025\nAs stated earlier, these unaccounted cash transactions as recorded above contain details of cash generated from sale of scrap, purchase adjustments/accommodations, sale of raw materials, sale of immovable property, interest received on loans advanced, repayment of such loans

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

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

36,659\n2,51,76,51,3151240661\n\nArivkumar\n06/01/22\n\nए. टी. वी. कमार, भारा से.\nKA TV. KUMAR. IR S.\n8.\n\n6/1/2025\n\nAs stated earlier, these unaccounted cash transactions as recorded above contain details of\ncash generated from sale of scrap, purchase adjustments/accommodations, sale of raw\nmaterials, sale of immovable property, interest received on loans advanced

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

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

36 of the Act, and suo moto disallowed the same by adding it back to the P&L account. It is only thereafter the business income of the assessee is computed in accordance with the principles laid down for computation of the profits and gains of business or profession in sections 28 to 44DB of the Act. By this

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

bogus invoices to route funds, the\nauthenticity of sales of cement as stated by the assessee is in\nquestion and hence, the explanation is not satisfactory. Hence, an\namount of Rs.1,29,91,000/- was added u/s 68.\n6.1 The appellant submitted all documentary evidences to prove that\nsales receipts from M/s Lakshin Infradev Pvt Ltd was genuine.\nAppellant relied

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

In the result, appeals filed by the Revenue are dismissed

Section 115BBE of the Income Tax Act, 1961 for the respective assessment years. 31. Aggrieved by the assessment order, the assessee preferred appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee submitted that, the impugned addition has been made on the basis of material found from the email account of Shri P. Anil Kumar, which contained