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

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

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. ACIT.,CENTRAL CIRCLE-1(2), HYDERABAD

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

c) of the proviso\nto section 148A of the Act, and initiated proceedings on the\npremises that the case of the assessee falls under clause (a) of\n1st proviso to section 148A, then the approval/sanction granted\nby the DG IT(Inv) u/s 151 of the Act is also not based on the\nverification and application of mind on the relevant

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

c) of the proviso\nto section 148A of the Act, and initiated proceedings on the\npremises that the case of the assessee falls under clause (a) of\n1st proviso to section 148A, then the approval/sanction granted\nby the DG IT(Inv) u/s 151 of the Act is also not based on the\nverification and application of mind on the relevant

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

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

c) of the proviso\nto section 148A of the Act, and initiated proceedings on the\npremises that the case of the assessee falls under clause (a) of\n1st proviso to section 148A, then the approval/sanction granted\nby the DG IT(Inv) u/s 151 of the Act is also not based on the\nverification and application of mind on the relevant

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

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

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

c) of the proviso\nto section 148A of the Act, and initiated proceedings on the\npremises that the case of the assessee falls under clause (a) of\n1st proviso to section 148A, then the approval/sanction granted\nby the DG IT(Inv) u/s 151 of the Act is also not based on the\nverification and application of mind on the relevant

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

In the result, appeals of the assessee for the A

147 of the Act in\npursuant to the search & seizure action u/s 132 of the Act carried\nin case of the assessee and group concerns on 04/01/2023 as\nunder:\n\n“The reasons recorded for reopening of the assessment\nrecorded are as under:\n\n1. A search and seizure operation u/s 132 of the IT Act was\ncarried

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

In the result, appeals of the assessee for the A

147 of the Act in\npursuant to the search & seizure action u/s 132 of the Act carried\nin case of the assessee and group concerns on 04/01/2023 as\nunder:\n\n“The reasons recorded for reopening of the assessment\nrecorded are as under:\n\n1. A search and seizure operation u/s 132 of the IT Act was\ncarried

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

c. Section 148A(d) - to pass an order deciding whether or not it is a fit case for issuing a notice under section 148; and d. Section 148 - to issue a reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High Courts \"shall be deemed to have been issued under

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)

c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 153A or sub- section (2) of section 153C or after the completion of the assessment, whichever is earlier.” 15. Having given a thoughtful consideration

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

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

c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 153A or sub- section (2) of section 153C or after the completion of the assessment, whichever is earlier.” 15. Having given a thoughtful consideration

RASHID HUSSAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(3), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 153A or sub- section (2) of section 153C or after the completion of the assessment, whichever is earlier.” 15. Having given a thoughtful consideration

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

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

c. Section 148A(d) - to pass an order deciding whether or not it is a fit case for issuing a notice under section 148; and d. Section 148 - to issue a reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High Courts "shall be deemed to have been issued under

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

In the result appeals filed by the Revenue\nITA

149...........” Further sub Section(a)\nof Section 153A(1) provides for issuance of notice\nto the persons searched under Section 132 of the\nAct to furnish a return of income. However, the\nsecond proviso to Section 153 A of the said act\nmakes it clear that assessment relating to any\n assessment year filed within a period