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

seizure operation. Thus, that being the case, the proceedings u/s 147/148 could be initiated only as per clause (b) and clause (c) of the proviso to section 148A of the Act. For ready reference, section 148A is quoted as under: "148A. The Assessing Officer shall, before issuing any notice under section 148-, (a) conduct any enquiry, if required, with

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

seizure operation. Thus, that being the case, the proceedings u/s 147/148 could be initiated only as per clause (b) and clause (c) of the proviso to section 148A of the Act. For ready reference, section 148A is quoted as under: "148A. The Assessing Officer shall, before issuing any notice under section 148-, (a) conduct any enquiry, if required, with

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

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

seizure operation.\nThus, that being the case, the proceedings u/s 147/148 could be\ninitiated only as per clause (b) and clause (c) of the proviso to\nsection 148A of the Act. For ready reference, section 148A is\nquoted as under:\n“148A. The Assessing Officer shall, before issuing any\nnotice under section 148-,\n(a) conduct any enquiry, if required

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

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

seizure operation.\nThus, that being the case, the proceedings u/s 147/148 could be\ninitiated only as per clause (b) and clause (c) of the proviso to\nsection 148A of the Act. For ready reference, section 148A is\nquoted as under:\n“148A. The Assessing Officer shall, before issuing any\nnotice under section 148-,\n(a) conduct any enquiry, if required

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

seizure operation.\nThus, that being the case, the proceedings u/s 147/148 could be\ninitiated only as per clause (b) and clause (c) of the proviso to\nsection 148A of the Act. For ready reference, section 148A is\nquoted as under:\n\n“148A. The Assessing Officer shall, before issuing any\nnotice under section 148-,\n(a) conduct any enquiry

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

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

seizure operation.\nThus, that being the case, the proceedings u/s 147/148 could be\ninitiated only as per clause (b) and clause (c) of the proviso to\nsection 148A of the Act. For ready reference, section 148A is\nquoted as under:\n\n“148A. The Assessing Officer shall, before issuing any\nnotice under section 148-,\n(a) conduct any enquiry

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:

seizure operation. Thus, that being the case, the proceedings u/s 147/148 could be initiated only as per clause (b) and clause (c) of the proviso to section 148A of the Act. For ready reference, section 148A is quoted as under: "148A. The Assessing Officer shall, before issuing any notice under section 148-, (a) conduct any enquiry, if required, with

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

In the result, appeals of the assessee for the A

seizure operation. Thus, that\nbeing the case, the proceedings u/s 147/148 could be initiated\nonly as per clause (b) and clause (c) of the proviso to section 148A\nof the Act. For ready reference, section 148A is quoted as under:\n\n“148A. The Assessing Officer shall, before issuing any\nnotice under section 148-, \n\n(a) conduct any enquiry

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

In the result, appeals of the assessee for the A

search & seizure\noperation which is the very basis of the initiation of the\nproceedings. However, the proceedings are initiated on the\npremises that the seized material is found from the possession of\nthe assessee during the search & seizure operation of the\nassessee. The other glaring aspect of the matter is that only the\nreceipt side of the details

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

seizure operation. Thus, that being the case, the proceedings u/s 147/148 could be initiated only as per clause (b) and clause (c) of the proviso to section 148A of the Act. For ready reference, section 148A is quoted as under: “148A. The Assessing Officer shall, before issuing any notice under section 148-, (a) conduct any enquiry, if required, with

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD., HYDERABAD

search and seizure operations. The core of the assessee's challenge was the validity of the notice issued under Section 148.", "held": "The Tribunal held that the notices issued under Section 148 were bad in law and void ab initio. This was due to the Assessing Officer failing to fulfill the conditions prescribed for issuing such notices beyond three years

RAM MOHAN RAO DARUMAGARI ,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-15(1), HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.467/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Shri Ram Mohan Rao Vs. Income Tax Officer Darumagari, Secunderabad Ward-15(1) Pan:Agapd7084P Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.466/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Late Vanaja Darumagari Vs. Income Tax Officer L/R Shri Ram Mohan Rao Ward-15(1) Darumagari, Secunderabad Hyderabad Pan:Akqpd6499Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Arun Lal, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 21/11/2024 घोषणा की तारीख/Pronouncement: 22/01/2025 आदेश/Order Per Vijay Pal Raothese Two Appeals By The Husband & Wife Are Directed Against Two Separate Orders Dated 10/01/2019 Of The Learned Cit (A)-7, Hyderabad For The A.Y.2008-09. The Issues

seizure action on a 3rd person. The Hon'ble Supreme Court in the case of Pr. CIT vs. Abhisar Buildwell (P) Ltd reported in (2023) 454 ITR 212 has held in Para 14 as under: “14. In view of the above and for the reasons stated above, it is concluded as under: i) that in case of search under Section

LATE VANAJA DARUMAGARI L/R RAM MOHAN RAO DARUMAGARI,HYDERABAD vs. INCOME TAX OFFICER, WARD-15(1), HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.467/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Shri Ram Mohan Rao Vs. Income Tax Officer Darumagari, Secunderabad Ward-15(1) Pan:Agapd7084P Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.466/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Late Vanaja Darumagari Vs. Income Tax Officer L/R Shri Ram Mohan Rao Ward-15(1) Darumagari, Secunderabad Hyderabad Pan:Akqpd6499Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Arun Lal, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 21/11/2024 घोषणा की तारीख/Pronouncement: 22/01/2025 आदेश/Order Per Vijay Pal Raothese Two Appeals By The Husband & Wife Are Directed Against Two Separate Orders Dated 10/01/2019 Of The Learned Cit (A)-7, Hyderabad For The A.Y.2008-09. The Issues

seizure action on a 3rd person. The Hon'ble Supreme Court in the case of Pr. CIT vs. Abhisar Buildwell (P) Ltd reported in (2023) 454 ITR 212 has held in Para 14 as under: “14. In view of the above and for the reasons stated above, it is concluded as under: i) that in case of search under Section

ACE CONSTRUCTIONS,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

seizure operation at the residence of Sri Jayanth Kumar Dutta, certain incriminating material in the form of cheque book of M/s Royal Engineering, pendrives , copies of contents in pendrives and loose sheets were found and seized as annexure (i) A/JKD/Res/01 (cheque books) (ii) A/JKD/Res/04(pendrive) (iii) A/JKD/Res/05 (sheet no 14-23) which contains the information/ details Page

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -3(4), HYDERABAD vs. ROYAL ENGINEERING, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

seizure operation at the residence of Sri Jayanth Kumar Dutta, certain incriminating material in the form of cheque book of M/s Royal Engineering, pendrives , copies of contents in pendrives and loose sheets were found and seized as annexure (i) A/JKD/Res/01 (cheque books) (ii) A/JKD/Res/04(pendrive) (iii) A/JKD/Res/05 (sheet no 14-23) which contains the information/ details Page

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ACE CONSTRUCTIONS, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

seizure operation at the residence of Sri Jayanth Kumar Dutta, certain incriminating material in the form of cheque book of M/s Royal Engineering, pendrives , copies of contents in pendrives and loose sheets were found and seized as annexure (i) A/JKD/Res/01 (cheque books) (ii) A/JKD/Res/04(pendrive) (iii) A/JKD/Res/05 (sheet no 14-23) which contains the information/ details Page

ROYAL ENGINEERING,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

seizure operation at the residence of Sri Jayanth Kumar Dutta, certain incriminating material in the form of cheque book of M/s Royal Engineering, pendrives , copies of contents in pendrives and loose sheets were found and seized as annexure (i) A/JKD/Res/01 (cheque books) (ii) A/JKD/Res/04(pendrive) (iii) A/JKD/Res/05 (sheet no 14-23) which contains the information/ details Page

ACE CONSTRUCTIONS,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

seizure operation at the residence of Sri Jayanth Kumar Dutta, certain incriminating material in the form of cheque book of M/s Royal Engineering, pendrives , copies of contents in pendrives and loose sheets were found and seized as annexure (i) A/JKD/Res/01 (cheque books) (ii) A/JKD/Res/04(pendrive) (iii) A/JKD/Res/05 (sheet no 14-23) which contains the information/ details Page

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ACE CONSTRUCTIONS, HYDERABAD

In the result, appeal of Revenue in ITA No

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarsl. आ.अपी.सं / निर्धारणारण वर्ष अपीलार्थी / प्रत्‍यर्थी / No.

seizure operation at the residence of Sri Jayanth Kumar Dutta, certain incriminating material in the form of cheque book of M/s Royal Engineering, pendrives , copies of contents in pendrives and loose sheets were found and seized as annexure (i) A/JKD/Res/01 (cheque books) (ii) A/JKD/Res/04(pendrive) (iii) A/JKD/Res/05 (sheet no 14-23) which contains the information/ details Page