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

reassessment proceedings initiated under Section 147 of the Act, and if we go by the words used in the said provision, it refers to such income i.e., income escaping assessment under Section 147 of the Act. The appellant further claims that the department's reliance on the case of Goetze (India) Ltd. Vs. CIT (supra) can be distinguished as being

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.:

section 148 of the Act on 29.07.2022 without obtaining the approval of the prescribed authority is invalid and void. Page 23 of 24 ITA 669 of 2025 Sanjeev Kumar Nalam Consequently, the reassessment

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 taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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 taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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 taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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 taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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 taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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 taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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

In the result appeals filed by the Revenue\nITA

reassessment proceedings the assessee\ncannot claim deduction which was neither claimed nor\nallowed in original assessment and it is not open to the\nassessee to seek a review of concluded items. Since the\nproceedings under section 153A of the Act are\nanalogous to proceedings under section 147 of the Act to\nthe extent that these proceedings are for the benefit

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

reassessment proceedings the assessee\ncannot claim deduction which was neither claimed nor\nallowed in original assessment and it is not open to the\nassessee to seek a review of concluded items. Since the\nproceedings under section 153A of the Act are\nanalogous to proceedings under section 147 of the Act to\nthe extent that these proceedings are for the benefit

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

reassessment proceedings the assessee\ncannot claim deduction which was neither claimed nor\nallowed in original assessment and it is not open to the\nassessee to seek a review of concluded items. Since the\nproceedings under section 153A of the Act are\nanalogous to proceedings under section 147 of the Act to\nthe extent that these proceedings are for the benefit

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

reassessment proceedings the assessee\ncannot claim deduction which was neither claimed nor\nallowed in original assessment and it is not open to the\nassessee to seek a review of concluded items. Since the\nproceedings under section 153A of the Act are\nanalogous to proceedings under section 147 of the Act to\nthe extent that these proceedings are for the benefit

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:

23. The first proviso to section 148 of the Act refers to the approval of the specified authority being obtained before a notice under section 148 of the Act can be issued. Explanation 3 to section 148 of the Act specifies that the meaning of the term 'specified authority' as provided for in section

C5 INFRA PRIVATE LIMITED,SECUNDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), 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.332/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) C5 Infra (P) Ltd Vs. Acit Secunderabad Central Circle 2(3) Pan:Aafcc2138K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca Shri C. Maheshwar Reddy, Ca राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2025 घोषणा की तारीख/Pronouncement: 25/07/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated 10/03/2023 Of The Learned Cit (A)-12, Hyderabad, For The A.Y.2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

23 of 38 ITA No 332 of 2023 C5 Infra P Ltd Page 24 of 38 ITA No 332 of 2023 C5 Infra P Ltd 12. On a closure verification of the details filed by the assessee as well as the expenditure recorded in the books of account of the assessee, we find that the entire fuel expenses of Rs.1.10

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

reassessment, as the case may be, under the said sub-sections (1), (1A), (2), (3) and (3A) shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263 or section 264 is 23

DR. REDDYS, LABORATORIES LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

reassessment, as the case may be, under the said sub-sections (1), (1A), (2), (3) and (3A) shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263 or section 264 is 23

LAXMI VENKATA KRISHNA RICE CORPORATION,NALGONDA vs. ITO, WARD-1, SURYAPET

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

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

reassessment proceedings was granted by the Commissioner of Income Tax after expiry of 3 years from the end of the relevant assessment year, which approval should have been granted by the Principal Chief Commissioner of Income Tax. 22. We, thus, in terms of our aforesaid observations, concur with the Ld. AR that in the present case before

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)

reassessment of total income or loss of assessee. (Emphasis supplied) 21. Similarly, the CBDT earlier also vide order dated 06.09.2021, in exercise of its powers under Section 119 of the Act introduced certain exceptions / exclusions to Section 144B of the Act. The said order dated 06.09.2021, for ready reference is again reproduced hereunder: Section 144B(2) of the Income