RAM GOPAL,HYDERABAD vs. ITO, WARD-8(2), HYDERABAD

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

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

147 with the prior approval of the Jt. Commissioner of Income Tax, Range-8 Hyderabad. Accordingly notice u/s 148 of the Act was issued on 27.3.2015 which was served on the assessee on 30.03.2015. 2.2 The Assessing Officer thereafter issued statutory notices u/s 143(2) and 142(1) of the Act calling for certain information regarding the transaction. The assessee

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED, HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

147 of the Income Tax Act, 1961 (“the Act”) for the reasons recorded, as per which, the information available with the department reveals that during the F.Y.2013-14, relevant to A.Y.2014-15, the assessee had made purchases to the tune of Rs.2,20,81,719/- from M/s Jagannath Agro Ltd. and such financial transaction has been reported to be bogus in nature

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED , HYDERABAD

In the result, all the three appeals filed by the Revenue for the A

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.980/Hyd/2024, 1079/Hyd/2024 & 1080/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19, 2014-15 & 2015-16) Dcit Vs. M/S Rohini Minerals Circle-3(1) Private Limited Hyderabad Hyderabad [Pan :Aaccr0773N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By: Shri B Bala Krishna, Cit-Dr Shri Srinath Sadanala, Sr.Ar

147 of the Income Tax Act, 1961 (“the Act”) for the reasons recorded, as per which, the information available with the department reveals that during the F.Y.2013-14, relevant to A.Y.2014-15, the assessee had made purchases to the tune of Rs.2,20,81,719/- from M/s Jagannath Agro Ltd. and such financial transaction has been reported to be bogus in nature

AMARAVATI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

u/s 147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report

AMARAVATI,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

u/s 147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report

AMARAVATI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

u/s 147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report

AMARAVATI ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee in ITA

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

u/s 147 r.w. section 148 of the Income Tax Act 1961('the Act') were not satisfied and therefore, the order of the Ld.CIT (A) upholding the initiation of reassessment proceedings as valid is erroneous, invalid and unsustainable in law. 2. The Ld.CIT (A) failed to appreciate that the reassessment proceedings and recording of reasons emanated from the report

DCIT., CIRCLE 3(1), HYDERABAD vs. ROHINI MINERALS PRIVATE LIMITED, HYDERABAD

In the result, all the three appeals filed by the Revenue for\nthe A

reassessment. Further upon consideration of the\nobjections, if any filed by the assessee, order u/s 148A(d) dated\n28.07.2022 was passed, as a consequence, notice u/s 148 of\nthe Act dated 29.07.2022 was issued and served on the\nassessee. In response to the notice u/s 148 of the Act, the\nassessee had filed return of income on 25.08.2022, declaring\ntotal

MEENA JEWELS AND PEARLS,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

u/s 10138) of the Act.\" 6. Keeping in view of the facts and circumstances of the present case and respectfully following the order of the Tribunal, SMC Bench, Delhi in the case of Smt. Jyoti Gupta vs. ITO (Supra) and in view of the law settled by the Hon'ble Supreme Court of India in the case of Andaman Timber

KINETA GLOBAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

purchases which the assessee company had claimed to have made from M/s. Sauve Corporation India Pvt. Ltd, were bogus and, thus, the entire amount of bogus expenditure was treated by him as the income of the assessee company. The AO, based on his aforesaid observations after reducing the profit of Rs. 18,17,636/-, that the assessee company had claimed

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

purchase or acquisition of any asset. Therefore, the business transactions of sale of scrap or commission income etc, as well as the expenditure incurred in relation to the business activity would not constitute of an asset in terms of section 149(1)(b) of the Act. It is also a matter of fact and record that these transactions as found

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:

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2.2 Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause (i) of explanation

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

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2. 2. Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause

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

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2. 2. Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause

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

purchase transactions and cash received on sale of lands, etc to the tune of Rs.6,08,84,018/- for the AY: 2015-16. 2. 2. Further, as the AO upon considering the facts and circumstances of the case decided that the present case is 'a fit case' for issuance of notice u/s 148 of 1.T.Act, as per clause

DCIT., CIRCLE-2(1), HYDRABAD vs. KALPTARU INVESTMENTS PRIVATE LIMITED, HYDERABAD

In the result, appeal ITA

reassessment u/s 147 of\nthe Act. Thus, there is clear failure on part of the assessee to make full and true disclosure\nwhile filing return of income. Hence, I have reason to believe that income amounting to Rs\n4,43,18,656/- has escaped assessment due to failure on part of the assessee.\n7.\nBy not offering the income

SRUJITHA ANNAPAREDDY,SECUNDERABAD vs. INCOME TAX OFFICER, WARD-12(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No.253/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Surjitha Annapareddy Vs. Income Tax Officer Secunderabad Ward 12(1) Pan:Bnwpa6703L Hydrabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Y Srikanth Reddy, Dr सुनवाई की तारीख/Date Of Hearing: 22/05/2024 घोषणा की तारीख/Pronouncement: 22/05/2024

147, the AO has to form a prima facie opinion on the basis of tangible material that there is an escapement of income, the opinion formed may be subjective but the reasons recorded or the information available on record must show that the opinion is not a mere suspicion, the reasons recorded and/or the documents available on record must show

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals of the assessee for the A

u/s 148 of the Act, if the alleged income is represented\nby any asset or expenditure. It is apparent on the face of the\nshow-cause notice( in brief "SCN"), that assessing officer is\nnot certain, as to whether in assessee`s case, the alleged\nescaped income is represented by asset or expenditure, both\nthese phrases have been issued