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

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD., HYDERABAD

sections": [ "143(3)", "147", "148", "149(1)(b)", "151", "148A" ], "issues": "The validity of the reassessment proceedings initiated by issuing notice u/s

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

RR MARKETING,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

u/s. 148 of the\nAct, wherein the escapement of income was below the threshold limit\nof Rs.50 lakhs.\n2. The Appellant, with the leave of the Hon'ble Tribunal, desires to raise\nthe following additional ground, without prejudice to the grounds raised\nin the appeal memorandum.\"\nAs the assessee firm by raising the additional ground of appeal\nhas sought

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

In the result, appeals of the assessee for the A

section\n149(1)(b) of the Act, empowers an authority to issue\nnotice 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

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

In the result, appeals of the assessee for the A

u/s 148A(d) and /\nor issuance of notice\nunder section 148 of the\nIncome Tax Act, 1961\nImproper many is\ncovered w/1149(1)(b).\nIsame of motive of/5148\nis ayyun.\n\nDate: 6/10/23\n\nPage 52 of 78\n\n28.\nThough there is a recommendation by the Pr. CIT,\nhowever, the sanction/approval granted by the DG reveals that it\nhas

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

In the result, all the appeals of the assessee for the\nA

149(1) of the Act. The Rajkot Bench of the Tribunal in\nthe case of Mukesh Manekchand Shety vs. Dy. CIT in ITA\nNo.581, 545 to 547.Rjt/2024 videorder dated 10/06/2025\nhas considered and decided an identical issue in para 40 as\nunder:\n\n“40. In the context of the above provisions of section\n149(1)(b

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

In the result, all the appeals of the assessee for the\nA

149(1) of the Act. The Rajkot Bench of the Tribunal in\nthe case of Mukesh Manekchand Shety vs. Dy. CIT in ITA\nNo.581, 545 to 547.Rjt/2024 videorder dated 10/06/2025\nhas considered and decided an identical issue in para 40 as\nunder:\n“40. In the context of the above provisions of section\n149(1)(b

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

In the result, all the appeals of the assessee for the\nA

149(1) of the Act. The Rajkot Bench of the Tribunal in\nthe case of Mukesh Manekchand Shety vs. Dy. CIT in ITA\nNo.581, 545 to 547.Rjt/2024 videorder dated 10/06/2025\nhas considered and decided an identical issue in para 40 as\nunder:\n\n“40. In the context of the above provisions of section\n149(1)(b

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

In the result, all the appeals of the assessee for the\nA

149(1) of the Act. The Rajkot Bench of the Tribunal in\nthe case of Mukesh Manekchand Shety vs. Dy. CIT in ITA\nNo.581, 545 to 547.Rjt/2024 videorder dated 10/06/2025\nhas considered and decided an identical issue in para 40 as\nunder:\n“40. In the context of the above provisions of section\n149(1)(b

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

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

149, Section 151, and Section 153, but not Chapter VI-A. Further, Section 153A(1)(a) states that the provisions of the Act shall apply as if it were a return :11: ITA Nos. 1717 to 1720/Hyd/2017 & required to be furnished under Section 139, and therefore, fresh claims can be made in such return in a manner similar to making

PEDA SUBBA RAO UNNAM,ADDANKI vs. ITO , WARD-1, ONGOLE

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

147. The only income that escaped assessment was the interest income of ₹31,807. Since this is below ₹1,00,000, the notice u/s 148 should have been issued within 4 years (i.e., by 31.03.2020) as per Section 149(1)(a). Argument: The addition of ₹12,90,000 u/s 69A is being challenged separately. For the purpose of determining

HEMALATHA CHERVU,HYDERABAD vs. ITO, WARD - 15(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1966/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Smt. Hemalatha Chervu Vs. Income Tax Officer Hyderabad Ward 15 (1) Pan:Aodpc8304C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Akash Deshpande, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 25/02/2026 घोषणा की तारीख/Pronouncement: 26/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 06/11/2025, For The A.Y 2015-16. 2. The Brief Facts Of The Case Are That The Assessee, An Individual, Not Filed Her Return Of Income For The A.Y 2015-16. The Page 1 Of 11

u/s 148 of the Act on or before 31/03/2022. Since the time limit available for issue of notice under section 148 of the Page 5 of 11 ITA No 1966 of 2025 Hemalatha Chervu Act as per the old regime of the assessment was up to 31/03/2022, in our considered view, the A.O cannot issue re- assessment notice under section

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

section 149(1) (a) of the Act. Since the impugned notice issued u/s.148 of the LT Act, 1961 dated 30.03.2023, legal and unsustainable in law, accordingly, the impugned reassessment order u/s.147 r.w.s.144B of the Act dated 01.03.2024 and the notice of demand dated 01.03.2024 Issued u/s 158 of the Act are also bad in law and unsustainable and the same

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, both the appeals filed by the assessee in ITA Nos

149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003 [but on or before the 31st day of March, 2021], the Assessing Officer shall— (a) issue notice to such

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)

149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003 [but on or before the 31st day of March, 2021], the Assessing Officer shall— (a) issue notice to such