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

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: “The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

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:

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

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

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

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

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

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

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

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

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

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: “The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

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

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

147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee and group concerns on 04/01/2023 as under: “The reasons recorded for reopening of the assessment recorded are as under: 1. A search and seizure operation u/s 132 of the IT Act was carried out by the ADIT

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.

reassessment regime under section 147 of the Income- tax Act, 1961. This new regime was introduced through significant amendments to section 147 and section 148, along with the insertion of Explanations 1 and 2, and the concept of "information suggesting escapement of income" was explicitly defined. From the reading of Explanation 2 to Section 147, it is evident that

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.

reassessment regime under section 147 of the Income- tax Act, 1961. This new regime was introduced through significant amendments to section 147 and section 148, along with the insertion of Explanations 1 and 2, and the concept of "information suggesting escapement of income" was explicitly defined. From the reading of Explanation 2 to Section 147, it is evident that

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

147 of the Act, for approval of the DGIT (Inv.) had given elaborate reasons and satisfaction that during the course of search and seizure action under section 132 of the Act it was found that the assessee has unaccounted cash receipts from scrap sale and the assessee had admitted undisclosed income of Rs.3,55,81,180/- for the year under

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

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

147 of the Act, for approval of the DGIT (Inv.) had given elaborate reasons and satisfaction that during the course of search and seizure action under section 132 of the Act it was found that the assessee has unaccounted cash receipts from scrap sale and the assessee had admitted undisclosed income of Rs.3,55,81,180/- for the year under

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147 or 263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147 or 263 proceedings are pending. The order u/s. 143(1) is placed at pages 211-222 of paper book volume-2. Referring to pages 223-227 of the paper book volume-2, he submitted that the AO in the order passed u/s. 143(3) for AY 2020-21 has allowed the claim of deduction u/s. 80IA. Referring

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.:

u/s. 147 of the Act had been revamped vide the Finance Act, 2021 w.e.f. 01.04.2021. The substituted Sections 147 to 149 and Section 151 of the Act, applicable w.e.f. 01.04.2021 are culled out as under: “Income escaping assessment- 147. If any income chargeable to tax, in the case of an assessee, has escaped assessment for any assessment year, the Assessing

KAPIL FOOD AND STRUCTURE PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

4 years when original assessment has been completed 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

KAPIL INFRA AVENUES PRIVATE LIMITED ,VIJAYAWADA vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

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

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

4 years when original assessment has been completed 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

KAPIL PROPERTY DEVELOPERS LIMITED ,HANUMAKONDA vs. DY COMMISSIONER OF INCOME TAX , HYDERABAD

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

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

4 years when original assessment has been completed 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

INCOME TAX OFFICER, WARD 3(1), HYDERABAD vs. STYPACK PRIVATE LIMITED , HYDERABAD

In the result, the appeal of the revenue is dismissed, while the cross-objection of the assessee company is allowed in terms of our aforesaid observations

Bench: Us:

132 of the Act on Shri Naresh Jain, an infamous accommodation entry provider and his syndicate members on 19.03.2019, initiated proceedings u/s 147 of the 4 ITA No.997/Viz/2024 & CO No.27/Hyd/2024 Stypack Private Limited Act. Order u/s 148A(d) of the Act was passed by the A.O., followed by a notice u/s 148 of the Act, dated 28.04.2022. 4. During