ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU , HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

3) r.w.s. 147 was passed on 21.07.2010. On review, the CIT(C) found that key issues, including diversion of funds and the opening balance of the suspense account as on 01.04.2002, were not considered. Investigations into M/s Satyam Computer Services Ltd. in 2010 revealed possible fund diversion from ADS proceeds amounting to Rs.193.00 crores as per the KPMG forensic audit

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

131 or section 133A, as the case may be, on or before the 31st day of March of a finacial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

NALGONDA REALTORS PRIVATE LIMITED ,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

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

131 or section 133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes

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

131 or section 133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes

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

131 or section 133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes

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:

131 or section 133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes

MBS JEWELLER PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3, HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

147 dated 27.12.2017. 6. It is also humbly submitted that additional evidence in the form of order of SEBI with regard to manipulation of share price of M/s Gold Stone Technologies Private Limited was filed by the undersigned on 13.05.2019. As the manipulation of share price of said company coupled with settlement of liabilities made by the assessee on behalf

MBS IMPES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

147 dated 27.12.2017. 6. It is also humbly submitted that additional evidence in the form of order of SEBI with regard to manipulation of share price of M/s Gold Stone Technologies Private Limited was filed by the undersigned on 13.05.2019. As the manipulation of share price of said company coupled with settlement of liabilities made by the assessee on behalf

RAMA MOHAN SOMA,ANANTAPUR vs. INCOME TAX OFFICER, WARD -1, HINDUPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2012-13 Rama Mohan Soma, Vs. The Income Tax Officer, H.No.12-274-3, Bypass Ward – 1, Road, Kadiri, Anantapur, Hindupur. Andhra Pradesh – 515591. Pan : Aocps8172D (Appellant) (Respondent) Assessee By: Shri G. Srinivasa Rao, C.A. Revenue By: Shri Shakeer Ahamed, Sr.Ar. Date Of Hearing: 02.05.2024 Date Of Pronouncement: 09.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2012-13 Arises From Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dt.27.12.2023 Invoking Proceedings Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short, “The Act”). 2. The Grounds Raised By The Assessee Read As Under :

131 issued. Hence, the AO has passed order u/s 143(3) rws 147. (2) It is verified from the Asst Record that no DIN is mentioned on the order. The assessee has taken a specific ground on this issue. You are requested to furnish proof of DIN generated & communicated to the assessee in respect of the Asst Order

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

3. Fenoplast Ltd. Vs. ACIT, [2014] 367 ITR 761 (T&AP) 4. E.N. Gopakumar Vs. CIT, 390 ITR 131 (Ker.) [2017] 5. M/s KCEL-MEIL (JV) and others in ITA No. 323/H/14 and others, order dated 13/01/2015. 6. M/s KNR Constructions Ltd., Hyd. in ITA No. 946/H/18 and others, order dated 16/10/2015. 7. Transstory (India

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

3. Fenoplast Ltd. Vs. ACIT, [2014] 367 ITR 761 (T&AP) 4. E.N. Gopakumar Vs. CIT, 390 ITR 131 (Ker.) [2017] 5. M/s KCEL-MEIL (JV) and others in ITA No. 323/H/14 and others, order dated 13/01/2015. 6. M/s KNR Constructions Ltd., Hyd. in ITA No. 946/H/18 and others, order dated 16/10/2015. 7. Transstory (India

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURES LIMITED, HYD, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

3. Fenoplast Ltd. Vs. ACIT, [2014] 367 ITR 761 (T&AP) 4. E.N. Gopakumar Vs. CIT, 390 ITR 131 (Ker.) [2017] 5. M/s KCEL-MEIL (JV) and others in ITA No. 323/H/14 and others, order dated 13/01/2015. 6. M/s KNR Constructions Ltd., Hyd. in ITA No. 946/H/18 and others, order dated 16/10/2015. 7. Transstory (India

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

3. Fenoplast Ltd. Vs. ACIT, [2014] 367 ITR 761 (T&AP) 4. E.N. Gopakumar Vs. CIT, 390 ITR 131 (Ker.) [2017] 5. M/s KCEL-MEIL (JV) and others in ITA No. 323/H/14 and others, order dated 13/01/2015. 6. M/s KNR Constructions Ltd., Hyd. in ITA No. 946/H/18 and others, order dated 16/10/2015. 7. Transstory (India

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

3. Fenoplast Ltd. Vs. ACIT, [2014] 367 ITR 761 (T&AP) 4. E.N. Gopakumar Vs. CIT, 390 ITR 131 (Ker.) [2017] 5. M/s KCEL-MEIL (JV) and others in ITA No. 323/H/14 and others, order dated 13/01/2015. 6. M/s KNR Constructions Ltd., Hyd. in ITA No. 946/H/18 and others, order dated 16/10/2015. 7. Transstory (India

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LIMITED, HYD, HYDERABAD

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

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

3. Fenoplast Ltd. Vs. ACIT, [2014] 367 ITR 761 (T&AP) 4. E.N. Gopakumar Vs. CIT, 390 ITR 131 (Ker.) [2017] 5. M/s KCEL-MEIL (JV) and others in ITA No. 323/H/14 and others, order dated 13/01/2015. 6. M/s KNR Constructions Ltd., Hyd. in ITA No. 946/H/18 and others, order dated 16/10/2015. 7. Transstory (India

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

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

131 or section 133A, as the case may be, on or before the 31st day of March of a finacial year, in consequence of: (a) a search u/s 132 which is initiated; or (b) a search u/s 132 for which the last of authorization is executed or (c) a requisition made u/s 132A Provided also that for the purposes