INTERWRAP CORP PRIVATE LIMITED (SUCCESSOR OF OWENS CORNING INDUSTRIES (INDIA) PRIVATE LIMITED),MUMBAI 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 VIJAY PAL RAO, HON'BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

154 was passed on 19.08.2021, revising the purchase adjustment to Rs. 49,86,32,000/-. 6. Thereafter, the A.O. passed a draft assessment order under Section 143(3) r.w.s. 144C(1) of the Act on 21.09.2021, determining the total income at Rs. 69,97,35,729/-, by incorporating the above transfer pricing adjustments. Aggrieved, the assessee filed objections before

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

3 companies put\ntogether for all assessment years. Out of such unaccounted\nincome, an amount of Rs 39.25 crores pertains to the assessee\ncompany for all the A.Ys.\n4.\nThe case was selected for scrutiny and during the\ncourse of assessment proceedings, the A.O on the basis of\nincriminating material found during the course of search coupled\nwith the statement

INCOME TAX OFFICER, WARD-1, NELLORE vs. VENKATA RAMANAMMA SAKAMURI, NELLORE

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

Bench: Us:

154 taxmann.com 159/457 ITR 647 (Bombay), held that where the Assessing Officer issued a reopening notice beyond the period of three years, approval was required to be taken as per provisions of amended section 151 from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. The relevant observations of the Hon'ble High Court

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

3 companies put\ntogether for all assessment years. Out of such unaccounted\nincome, an amount of Rs 39.25 crores pertains to the assessee\ncompany for all the A.Ys.\n\n4.\nThe case was selected for scrutiny and during the\ncourse of assessment proceedings, the A.O on the basis of\nincriminating material found during the course of search coupled\nwith

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes on the above terms

Bench: Shri R.K. Panda & Shri Laliet Kumar

reassessment or re-computation, as envisaged in Section 132B(1)(i) of the Act. The Appellant in this regard three orders passed by Hon’ble ITAT Benches viz., (i) ACIT Vs. Narendra N. Thacker [(2016) 45 ITR Trib 188 (Kol)]; (ii) unreported judgement in ACIT Vs. Sajjan Singh and (iii) unreported order in Arun Bansal, Delhi Vs. ACIT, Delhi

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 order are vitiated in lew. 3. The learned CIT(A) erred in confirming the addition of Rs. 30,17,000/- made under Section 63A of the Act by the Assessing Officer without any independent verification or reconciliation. The authorities failed to refute the explanations provided with cogent evidence rendering the addition unsustainable. 4. The learned CIT(A) failed

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.

3 companies put together for all assessment years. Out of such unaccounted income, an amount of Rs.26.22 crores pertains to the assessee company for all the A.Ys. For the A.Y 2020-21, the assessee company admitted Rs.1.82 crores during the course of search proceedings. However, while filing the return of income in response to notice under section

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.

3 companies put together for all assessment years. Out of such unaccounted income, an amount of Rs.26.22 crores pertains to the assessee company for all the A.Ys. For the A.Y 2020-21, the assessee company admitted Rs.1.82 crores during the course of search proceedings. However, while filing the return of income in response to notice under section

G R N CONSTRUCTIONS PRIVATE LIMITED,NELLORE vs. DCIT., CIRCLE-1, NELLORE

Bench: Us:

3) of Section 14A provides for the application of sub section (2) also to a situation where the assessee claims that no expenditure has been incurred by him in relation to income 9 which does not form part of the total income under the Act. Under the proviso, it has been stipulated that nothing in the section will empower

VIJAYARAGHAVAN LAKSHMI,,CHENNAI vs. ACIT, CIRCLE-1(2), HYDERABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2016-17 Mrs. Vijayaraghavan Vs. Acit, Central Circle-1(2) Lakshmi Aaykar Bhawan Ground Floor, Block-A Opp:L.B.Stadium Prince Villa, New No.15 Basheerbagh Rajamannar Street Hyderabad Teynampet Chennai-600 018 Tamilnadu

section 154 were also brought to the notice of the ld.CIT(A). 3 ITA 260/Hyd/2022 4. However, the ld.CIT(A) was not satisfied with the arguments advanced by the assessee and upheld the 154 order passed by the AO by observing as under:- 6. In the instant case, notice u/s. 153A was issued to the appellant and no return

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

154 and Explanation 1 (f) to section 115JB being squarely covered, the same cannot be found fault with. We are of the considered view that the Miscellaneous Petition filed by the revenue under section 254(2) of the Act was wholly misconstrued. The Tribunal has distinguished the case of Sobha Developers (supra) relied upon by the revenue with VireetInvestment

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

RR MARKETING,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

154 of the Act\non the same issue, it cannot be made. The attention of this Court\nhas been drawn to the notice dated 20.01.2022 issued for\nrectification of mistake and the order under Section 148A(d) of\nthe Act passed on 22.04.2024. Reliance has been placed on the\nfollowing decisions rendered by the Apex Court in Union of India

NAVDURGA TRANSPORT COMPANY,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(1), HYDERABAD

Appeal is allowed in terms of our aforesaid observations

Bench: Us:

reassessment proceedings, we are 7 ITA 218 and 219/Hyd/2025 Navadurga Transport Company vs. ITO unable to persuade ourselves to accept the same. As observed by the CIT(A) and rightly so, as the AO at the stage of initiation of proceedings under section 147 of the Act is only required to have some material available with him, based on which

NAVDURGA TRANSPORT COMPANY,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(1), HYDERABAD

Appeal is allowed in terms of our aforesaid observations

Bench: Us:

reassessment proceedings, we are 7 ITA 218 and 219/Hyd/2025 Navadurga Transport Company vs. ITO unable to persuade ourselves to accept the same. As observed by the CIT(A) and rightly so, as the AO at the stage of initiation of proceedings under section 147 of the Act is only required to have some material available with him, based on which

AMITH VISHNAV GUDIMELLA,HYDERABAD vs. ITO, WARD-12(1), HYDERABAD, HYDERABAD

In the result, appeal of the Assessee is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

3)(a) of the DTAA r. w. section 90 of the Act and such FTC approved to the assessee cannot be denied on the grounds of non- compliance of procedural requirements prescribed in the Rules which are subservient to the Act as well as DTAA. The assessee further contended that provisions of DTAA override the 13 ITA.No.1705/Hyd./2025 provisions

SURESH KUMAR VOBBILISETTY,HYDERABAD vs. INCOME TAX OFFICER, INTERNATIONAL TAXATION-2, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1204/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) Shri Suresh Kumar Vs. Income Tax Officer Vobbilisetty, (International Taxation)-2 Hyderabad Hyderabad Pan:Acgpv5441G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca K Hemalatha राज" व "ारा/Revenue By:: Shri Kumar Aditya, Dr सुनवाई की तारीख/Date Of Hearing: 15/01/2025 घोषणा की तारीख/Pronouncement: 07/03/2025 आदेश/Order

3)(a) of the DTAA r. w. section 90 of the Act and such FTC approved to the assessee cannot be denied on the grounds of non-compliance of procedural requirements prescribed in the Rules which are subservient to the Act as well as DTAA. The assessee further contended that provisions of DTAA override the provisions of the Income

SRIDHARAN VENKATANARAYANAN,SECUNDERABAD vs. DCIT., CIRCLE- 12(1), 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 No.32/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Sri Sridharan Vs. Dy. Commissioner Of Venkatanarayanan Income Tax, Circle 12(1) Secunderabad Hyderabad Pan:Bgaps6316N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A V. Balaji राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 24/03/2025 घोषणा की तारीख/Pronouncement: 27/03/2025 आदेश/Order

3)(a) of the DTAA r. w. section 90 of the Act and such FTC approved to the assessee cannot be denied on the grounds of non-compliance of procedural requirements prescribed in the Rules which are subservient to the Act as well as DTAA. The assessee further contended that Page 7 of 11 ITA 32 of 2025 Sridharan Venkatanarayanan