WESTERN UP TOLLWAY LIMITED,NEW DELHI vs. DCIT CIRCLE -8(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

reassessment [or fresh order under section 92CA, as the case may be], such effect shall be given within a period of three months from the end of the month in which order under section 250 or section 254 or section 260 or section 262 is received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner

MAHUA BHARATPUR EXPRESSWAYS LIMITED, ,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

reassessment [or fresh order under section 92CA, as the case may be], such effect shall be given within a period of three months from the end of the month in which order under section 250 or section 254 or section 260 or section 262 is received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

13. We shall first deal with the Ld. DR’s contention that as the assessee has within the specified time period contemplated under sub- section (3) of Section 124 of the Act, i.e., within a period of one month from the date on which the said notice was served upon him not called in question the jurisdiction of the ACIT

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

13. We shall first deal with the Ld. DR’s contention that as the assessee has within the specified time period contemplated under sub- section (3) of Section 124 of the Act, i.e., within a period of one month from the date on which the said notice was served upon him not called in question the jurisdiction of the ACIT

TMEIC INDUSTRIAL SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 2(1), HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.898/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) M/S. Tmeic Industrial Vs. Dy.Cit Systems India Private Limited Circle 2(1) Hyderabad Hyderabad Pan: Aadct5493J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.As, K. C. Devdas, Kranthi Palivela & Mrudulatha राज" व "ारा/Revenue By: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 08/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

reassessment [or fresh order under section 92CA, as the case may be], such effect shall be given within a period of three months from the end of the month in which order under section 250 or section 254 or section 260 or section 262 is received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

RASHID HUSSAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(3), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

13. We shall first deal with the Ld. DR’s contention that as the assessee has within the specified time period contemplated under sub- section (3) of Section 124 of the Act, i.e., within a period of one month from the date on which the said notice was served upon him not called in question the jurisdiction of the ACIT

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

13) r.w.s. 144B of the Act, is governed by the provisions of Section 153(1) and Section 153(4) of the Act, and if the final assessment order passed by the A.O. is beyond the time limit provided under Section 153(1) and 153(4) of the Act, then it is barred by limitation and is liable to be quashed

CONCENTRIX CATALYST TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

reassessment [or fresh order under section 92CA, as\nthe case may be], such effect shall be given within a period of three\nmonths from the end of the month in which order under section\n250 or section 254 or section 260 or section 262 is received by the\nPrincipal Chief Commissioner or Chief Commissioner or Principal\nCommissioner or Commissioner

RAMESH BABU BEJJALA,KOTHAGUDEM vs. INCOME TAX OFFICER, WARD-1, KOTHAGUDEM

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

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

reassessment or recomputation to be made in pursuance of the notice is to be made on him as the agent of such non-resident, the notice shall not be issued after the expiry of a period of six years from the end of the relevant assessment year. Explanation For the removal of doubts, it is hereby clarified that the provisions

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

1(4), Mansa in ITA Nos. 306 & 307/ASR/2019, dated 30.06.2021, wherein it was held as under:- "12. As regards to the validity of the reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. Copy

R.A.K CERAMICS INDIA PRIVATE LIMITED,SAMALKOT vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

reassessment [or fresh order under section 92CA, as\nthe case may be], such effect shall be given within a period of three\nmonths from the end of the month in which order under section\n250 or section 254 or section 260 or section 262 is received by the\nPrincipal Chief Commissioner or Chief Commissioner or Principal\nCommissioner or Commissioner

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

reassess the assessment already made without following the procedure under Section 147 or Section 148 of the Act and determine the total income of the assessee. The arguments raised by the counsel for the assessee, in light of the provisions of Section 153A(1)(a) and Form ITR-6, that the moment the assessee files a return in response

SAXON GLOBAL INDIA PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

13) r.w.s. 144B of the Act, is governed by the provisions of Section 153(1) and Section 153(4) of the Act and if the final assessment order passed by the A.O. is beyond the time limit provided under Section 153(1) and Section 153(4) of the Act then it is barred by limitation and is liable

ANKIT JAIN,HYDERABAD. vs. ACIT., CENTRAL CIRCLE - 1(2), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

13. We shall first deal with the Ld. DR’s contention that as the assessee has within the specified time period contemplated under sub- section (3) of Section 124 of the Act, i.e., within a period of one month from the date on which the said notice was served upon him not called in question the jurisdiction of the DCIT

ANKIT JAIN, HYDERABAD. vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD.

In the result, both the appeals filed by the assessee in ITA Nos

Bench: Us:

13. We shall first deal with the Ld. DR’s contention that as the assessee has within the specified time period contemplated under sub- section (3) of Section 124 of the Act, i.e., within a period of one month from the date on which the said notice was served upon him not called in question the jurisdiction of the DCIT

PAREXEL INTERNATIONAL (IRL) LIMITED,IRELAND vs. ADIT (INT TAXN)-2, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.447/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2020-21) Parexel International Vs. Additional Director Of (Irl) Limited, Ireland Income Tax Pan:Aaicp4417B Hyderabad (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Advocate Kanchun Kaushal राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Parexel International (Irl) Limited, Ireland (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Adit (Int. Taxation)-2, Hyderabad (“Ld. Ao”) Dated 07.07.2023 For The A.Y 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal:

reassessment [or fresh order under section 92CA, as the case may be], such effect shall be given within a period of three months from the end of the month in which order under section 250 or section 254 or section 260 or section 262 is received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner

SUDHA DOSHI,HYDERABAD vs. ITO - WARD 5(1), HYDERABAD

reassessment when there\nwas no suppression of facts on the part of the assessee which is\nevident from the original assessment order dated 29.09.2017 passed\nu/s 143(3).\n6. The CIT(A) erred in upholding the addition of Rs. 13,00,561/-made\nby the assessing officer as undisclosed business income vide para no.\n3 of the assessment order

CALLIDUSCLOUD (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section