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

201, SR Residency, Nizampet Road, Hyderabad which was gifted to my daughter at the time of her marriage. The details of movable assets held in my name and in the name of my wife are as under: (i) Swift Dezire four wheeler bearing registration number TS 09 EB 6421. 20 ITA.Nos.1870 to 1875/Hyd./2025 Q.8 Please explain the nature

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

201, SR Residency, Nizampet Road, Hyderabad which was gifted to my daughter at the time of her marriage. The details of movable assets held in my name and in the name of my wife are as under: (i) Swift Dezire four wheeler bearing registration number TS 09 EB 6421. 20 ITA.Nos.1870 to 1875/Hyd./2025 Q.8 Please explain the nature

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:

201, SR Residency, Nizampet Road, Hyderabad which was gifted to my daughter at the time of her marriage. The details of movable assets held in my name and in the name of my wife are as under: (i) Swift Dezire four-wheeler bearing registration number TS 09 EB 6421. Q.8 Please explain the nature of business of M/s ERPL

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

201, SR Residency, Nizampet Road, Hyderabad which was gifted to my daughter at the time of her marriage. The details of movable assets held in my name and in the name of my wife are as under: (i) Swift Dezire four wheeler bearing registration number TS 09 EB 6421. Q.8 Please explain the nature of business of M/s ERPL

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

201, SR Residency, Nizampet Road, Hyderabad which was gifted to my daughter at the time of her marriage. The details of movable assets held in my name and in the name of my wife are as under: (i) Swift Dezire four wheeler bearing registration number TS 09 EB 6421. Q.8 Please explain the nature of business of M/s ERPL

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO ,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION) , NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLOR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. INDRANI PRASAD , NEW DELHI

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

1 April 2008. Section 292 BB of the Act provides a deeming fiction. The deeming fiction is to the effect that once the assessee has appeared in any proceeding or cooperated in. any enquiry relating to an assessment or reassessment, it shall be deemed that any notice under the provisions of the Act, which is required to be served

INDRANI PRASAD ,NEW DELHI vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, HYDERABAD

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

1 April 2008. Section 292 BB of the Act provides a deeming fiction. The deeming fiction is to the effect that once the assessee has appeared in any proceeding or cooperated in. any enquiry relating to an assessment or reassessment, it shall be deemed that any notice under the provisions of the Act, which is required to be served

DESU ENTERPRISES,ONGOLE vs. ITO., WARD-1, ONGOLE

In the result, the appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.549 & 589/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 & 2013-14) 1. M/S. Desu Enterprises, Ongole (A.P.) Pan: Aagfd1940C 2. Thalla Srisailam Goud, Ibrahimpatnam. Pan: Αιτpg3044K (Appellants) Vs. Income Tax Officer, Ward-1, Ongole. Income Tax Officer, Ward 9(1), Hyderabad. (Respondents) निर्धारिती द्वारा / Assessees By: राजस्व द्वारा / Revenue By: Shri Sashank Dundu, Advocate Ms. U. Mini Chandran, Cit-Dr & Ms. Payal Gupta, Sr-Dr सुनवाई की तारीख / Date Of Hearing: 06/11/2025 घोषणा की तारीख / Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Appeals Are Filed By M/S. Desu Enterprises & Shri Thalla Srisailam Goud (“The Assessees”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 26.02.2024 & 09.04.2024 For The A.Ys. 2015-16 & 2013-14 Respectively. Since The Issues Involved In These Two Appeals Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

1 Dear THALLA SRISAILAM GOUD, Please find attached the Notice u/s 148 for PAN:AITPG3044K and AY:2013-14. Please quote your PAN in all future correspondences. 8. On the basis of the above screen shot of Income Tax portal, the Ld. DR has contended that the notice under section 148 of the Act was dispatched through the Income

THALLA SRISAILAM GOUD,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 9(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

1). 3. The Ld. Commissioner of Income-tax (Appeals)/NFAC erred rejecting the legal grounds raised by the Appellant w.r.t. initiation of reassessment proceeding without following due procedure prescribed under the statute. 4. The NFAC ought to have appreciated that the Assessing Officer had not recorded proper satisfaction and further initiated reassessment proceedings under the old law beyond the period

ACIT,CIRCLE-13(1), HYDERABAD vs. M/S SURESH PRODUCTIONS PVT. LTD.,, HYDERABAD

Accordingly, the ground of the revenue is allowed

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

reassessment), and consequently the learned CIT(Appeals) did not adjudicate on this additional ground raised before him. 2) For the above grounds and such other grounds that may be urged at the time of hearing, the Respondent prays that the cross objections be allowed. 3) The Respondent craves leave to add to, amend or modify the above grounds of cross

DCIT, CIRCLE-17(1), HYD, HYDERABAD vs. ECI ENGINEERING & CONSTRUCTION CO. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

1) (SC) 17. The ld. DR on the other hand heavily relied on the orders of the AO and CIT(A). So far as the validity of reassessment is concerned, he submitted that the AO in the original assessment order has neither discussed nor there was an opinion with respect to issue related to prior period expenditure as project expenses

ECI ENGINEERING & CONSTRUCTION COMPANY LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-2(2), HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

1) (SC) 17. The ld. DR on the other hand heavily relied on the orders of the AO and CIT(A). So far as the validity of reassessment is concerned, he submitted that the AO in the original assessment order has neither discussed nor there was an opinion with respect to issue related to prior period expenditure as project expenses

DAYA SHANKER TIWARI, HYDERABAD vs. INCOME TAX OFFICER, WARD-6(1), I T TOWER, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

1), Hyderabad. PAN ABSPT0309E PIN-500 004. Telangana. (Appellant) (Respondent) For Assessee : CA, K A Sai Prasad For Revenue : Shri Vinod Kannan, Sr. AR Date of Hearing : 05.08.2025 Date of Pronouncement : 08.08.2025 ORDER PER MANJUNATHA G. : The above appeal has been filed by the assessee against the order dated 17.03.2025 of the learned Commissioner of Income Tax-(Appeals)-National Faceless

GMR AIR CARGO & AEROSPACE ENGINEERING LTD(SUCCESSOR TO GMR HYDERABAD AIR CARGO & LOGISTICS PVT LTD),SHAMSHABAD vs. INCOME TAX OFFICER, WARD-2(3) , HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2008-09 Gmr Air Cargo & Vs. Ito,Ward-2(3) Aerospace Engineering Signature Towers Ltd.(Successor To Gmr Kondapur, Kothaguda Hyderabad Air Cargo & Opp. Botanical Gardens Logistics Pvt Ltd.) R.R.District Rajiv Gandhi International Hyderabad-500 084 Airport, Samshabad Hyderabad-500 409

1) (SC) 17. The ld. DR on the other hand heavily relied on the orders of the AO and CIT(A). So far as the validity of reassessment is concerned, he submitted that the AO in the original assessment order has neither discussed nor there was an opinion with respect to issue related to prior period expenditure as project expenses