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

133A was carried out in the case of the appellant on 22.02.2016 and the appellant had disclosed an additional income of Rs. 5,00,00,000/- for the year under consideration. The appellant, there after filed a revised return u/s. 139(5) on 21.12.2016 at an income of Rs. 9,70,04,260/- and claiming a deduction u/ s. 80IA

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

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

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 of computing the period

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

5 of 29\nITA Nos 1566 and 1571 Exel Rubber Private Ltd\nRamesh Kumar Sanaka was seized and the data in the Laptop was\ndownloaded to the Pen Drive which was also seized as Annexure\nA/RKS/RES/01. This fact was also recorded in the statement\nobtained from Shri. Ramesh Kumar Sanaka on 06/01/2023 vide\nquestion No. 58 to 61. This fact

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:

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

INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 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, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

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 159 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

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

133A of the Act, carried out in the case of JM Financial Asset Management Limited, for reopening a concluded assessment, under the facts and circumstances of the case. 4. Whether the learned Authorities below are justified in issuing notice under section 148 of the Act, beyond the limitation period which is bad in law, under the facts and circumstances

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)

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

THE PRAKASAM DISTRISET POLICE WELFARE ASSOCIATION,ONGOLE vs. ITO., WARD-1, ONGOLE

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

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 159 and Section 151 of the Act, applicable w.e.f. 01.04.2021 are culled out as under: “Income escaping assessment- 8 The Prakasam District Police Welfare Association vs. ITO 147. If any income chargeable to tax, in the case of an assessee

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:

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 159 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

KILARU VENKATA SATISH,KRISHNA DIST vs. DCIT, CENTRAL CIRCLE-1(3), HYDERABAD

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

Bench: Us), Which Reads As Under:

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 159 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

VENKATA RAMA KRISHNAM RAJU CHINTALAPATI,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

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

Bench: Us:

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 159 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

THULASI CHAMARTHY,CHITTOOR vs. INCOME TAX OFFICER, WARD - 1, CHITTOOR

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

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

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

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 of computing the period

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

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 of computing the period

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

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 of computing the period

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

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 159 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

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

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)

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 159 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

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:

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 of computing the period