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

132 of the Act and the consequent assessment proceedings under Section 153A of the Act, because the provisions of Section 153A of the Act are akin to the provisions of Section 147 of the Act and thus, as held by the Hon’ble Supreme Court in the case of CIT Vs. Sun Engineering Works (P) Ltd. (supra), reassessment

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

reassessment,\nif any, relating to any assessment year falling\nwithin the period of six assessment years and for\nthe relevant assessment year or years referred to\nin this sub- section pending on the date of initiation\nof the search under section 132

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

In the result appeals filed by the Revenue\nITA

reassessment,\nif any, relating to any assessment year falling\nwithin the period of six assessment years and for\nthe relevant assessment year or years referred to\nin this sub- section pending on the date of initiation\nof the search under section 132

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

reassessment,\nif any, relating to any assessment year falling\nwithin the period of six assessment years and for\nthe relevant assessment year or years referred to\nin this sub- section pending on the date of initiation\nof the search under section 132

DY.COMMISSIONER OF INCOME TAX, CIRCLE 2(2), HYDERBAD vs. SEW INFRASTUCTURE LIMITED, HYDERABAD

reassessment,\nif any, relating to any assessment year falling\nwithin the period of six assessment years and for\nthe relevant assessment year or years referred to\nin this sub- section pending on the date of initiation\nof the search under section 132

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

reassessment or re-\ncomputation under section 147, and subject to the provisions\nof section 148A, the Assessing Officer shall serve on the\nassessee a notice, along with a copy of the order passed, if\nrequired, under clause (d) of section 148A, requiring him to\nfurnish within such period, as may be specified in such\nnotice, a return of his income

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

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A 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: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

reassessment regime under section 147 of the Income- tax Act, 1961. This new regime was introduced through significant amendments to section 147 and section 148, along with the insertion of Explanations 1 and 2, and the concept of "information suggesting escapement of income" was explicitly defined. From the reading of Explanation 2 to Section 147, it is evident that

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

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A 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: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

reassessment regime under section 147 of the Income- tax Act, 1961. This new regime was introduced through significant amendments to section 147 and section 148, along with the insertion of Explanations 1 and 2, and the concept of "information suggesting escapement of income" was explicitly defined. From the reading of Explanation 2 to Section 147, it is evident that

MADHUCON PROJECTS LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132

ACIT CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132

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

reassessment proceedings void ab initio.", "result": "Allowed", "sections": [ "148", "143(3)", "144B", "132", "132(4)", "65B", "147", "151", "153C" ], "issues

EXPRESSWAY SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

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

reassessment in respect of each assessment year falling within six assessment years referred to in Section 153C r.w.s. Section 153A(1)(b) within a period of twelve months from the end of the financial year in which the last of the authorization for search under Section 132

EXPRESSWAY SERVICES PVT LTD,HYDERABAD vs. DCIT., CENTRAL CIRCLE -2(4), HYDERABAD

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

reassessment in respect of each assessment year falling within six assessment years referred to in Section 153C r.w.s. Section 153A(1)(b) within a period of twelve months from the end of the financial year in which the last of the authorization for search under Section 132

EXPRESSWAY SERVICES PVT LTD,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

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

reassessment in respect of each assessment year falling within six assessment years referred to in Section 153C r.w.s. Section 153A(1)(b) within a period of twelve months from the end of the financial year in which the last of the authorization for search under Section 132

SANJEEV KUMAR NALAM,HYDERABAD vs. ITO, WARD-1, NIRMAL

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.669/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Sanjeev Kumar Nalam Vs. Income Tax Officer Hyderabad Ward – 1 Pan:Avdpn0497L Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income