SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

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)

153D would be applicable in proceedings drawn under Section 153A and Section 153B. 29. Section 153A of the Act speaks of how assessment in a case of search and seizure or requisition is to be made. For ready reference, the relevant portion of Section 153A is also reproduced hereunder: "153A. Assessment in case of search or requisition. (1)Notwithstanding anything

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

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

153D would be applicable in proceedings drawn under Section 153A and Section 153B. 29. Section 153A of the Act speaks of how assessment in a case of search and seizure or requisition is to be made. For ready reference, the relevant portion of Section 153A is also reproduced hereunder: "153A. Assessment in case of search or requisition. (1)Notwithstanding anything

ANKIT JAIN,HYDERABAD. vs. ACIT., CENTRAL CIRCLE - 1(2), HYDERABAD

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

Bench: Us:

153D would be applicable in proceedings drawn under Section 153A and Section 153B. 29. Section 153A of the Act speaks of how assessment in a case of search and seizure or requisition is to be made. For ready reference, the relevant portion of Section 153A is also reproduced hereunder: "153A. Assessment in case of search or requisition. (1)Notwithstanding anything

ANKIT JAIN, HYDERABAD. vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD.

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

Bench: Us:

153D would be applicable in proceedings drawn under Section 153A and Section 153B. 29. Section 153A of the Act speaks of how assessment in a case of search and seizure or requisition is to be made. For ready reference, the relevant portion of Section 153A is also reproduced hereunder: "153A. Assessment in case of search or requisition. (1)Notwithstanding anything

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)

153D would be applicable in proceedings drawn under Section 153A and Section 153B. 29. Section 153A of the Act speaks of how assessment in a case of search and seizure or requisition is to be made. For ready reference, the relevant portion of Section 153A is also reproduced hereunder: "153A. Assessment in case of search or requisition. (1)Notwithstanding anything

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

u/s. Income Returned (Rs) Assessed Income (Rs.) 1 M/s. Swastik Vegetable Oil Products Pvt. Ltd. AADCS2224G 2012-13 143(3) r.w.s 153C of the 1.T. Act (8,54,540)/- 22,87,460/- 2 M/s. Swastik Vegetable Oil Products Pvt. Ltd. AADCS2224G 2013-14 143(3) r.w.s 153C

INDUKURI SYAM PRASAD REDDY, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeals of both assessee’s are allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blesmt Indukuri Sundari V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aakpi8049P (Appellant) (Respondent) Shri Indukuri Syam Prasad Reddy V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aadpi1621C (Appellant) (Respondent) : Shri Mohammad Afzal Assessee By Department By : Shri M.V.S.T. Sai

147, 148, 149, 151 and section 153 and not referred to section 263. Therefore, it is submitted that the directions issued in section 263 will not abate, therefore, the order consequent to order u/s.263 should have been passed on or before 31.03.2014 only. Therefore, having passed the same on 27.02.2015 is barred by limitation. It is further submitted that

INDUKURI SUNDARI, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(1), HYDERABAD, HYDERABAD

In the result, appeals of both assessee’s are allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blesmt Indukuri Sundari V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aakpi8049P (Appellant) (Respondent) Shri Indukuri Syam Prasad Reddy V. Dcit – Central Circle - 2(1) Plot No. 973/A, Road No. 49 Aayakar Bhavan Hyderabad Jubilee Hills Hyderabad – 500 033 Pan: Aadpi1621C (Appellant) (Respondent) : Shri Mohammad Afzal Assessee By Department By : Shri M.V.S.T. Sai

147, 148, 149, 151 and section 153 and not referred to section 263. Therefore, it is submitted that the directions issued in section 263 will not abate, therefore, the order consequent to order u/s.263 should have been passed on or before 31.03.2014 only. Therefore, having passed the same on 27.02.2015 is barred by limitation. It is further submitted that

SYED WARISUDDIN NAVEED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

147 taxmann.com 305 (Allahabad), has also considered identical issue and held that, prior approval of JCIT to draft assessment order prepared by the A.O. is essential as per mandate of Section 153D, however, where draft assessment order for 123 cases were placed before the approving authority on 30.12.2017 and 31.12.2017 and the final assessment order was passed

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

In the result, the remaining appeals filed by the assessees (at Sl

147 taxmann.com 305 (Allahabad), has also considered identical issue and held that, prior approval of JCIT to draft assessment order prepared by the A.O. is essential as per mandate of Section 153D, however, where draft assessment order for 123 cases were placed before the approving authority on 30.12.2017 and 31.12.2017 and the final assessment order was passed

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

In the result, the remaining appeals filed by the assessees (at Sl

147 taxmann.com 305 (Allahabad), has also considered identical issue and held that, prior approval of JCIT to draft assessment order prepared by the A.O. is essential as per mandate of Section 153D, however, where draft assessment order for 123 cases were placed before the approving authority on 30.12.2017 and 31.12.2017 and the final assessment order was passed

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

In the result, the remaining appeals filed by the assessees (at Sl

147 taxmann.com 305 (Allahabad), has also considered identical issue and held that, prior approval of JCIT to draft assessment order prepared by the A.O. is essential as per mandate of Section 153D, however, where draft assessment order for 123 cases were placed before the approving authority on 30.12.2017 and 31.12.2017 and the final assessment order was passed

MADHAVA REDDY BADDEVOLU,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

147 taxmann.com 305 (Allahabad), has also considered identical issue and held that, prior approval of JCIT to draft assessment order prepared by the A.O. is essential as per mandate of Section 153D, however, where draft assessment order for 123 cases were placed before the approving authority on 30.12.2017 and 31.12.2017 and the final assessment order was passed

RAGHUNATH REDDY GANGARAM,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2),, HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

147 taxmann.com 305 (Allahabad), has also considered identical issue and held that, prior approval of JCIT to draft assessment order prepared by the A.O. is essential as per mandate of Section 153D, however, where draft assessment order for 123 cases were placed before the approving authority on 30.12.2017 and 31.12.2017 and the final assessment order was passed

SYED WARISUDDIN NAVEED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

147 taxmann.com 305 (Allahabad), has also considered identical issue and held that, prior approval of JCIT to draft assessment order prepared by the A.O. is essential as per mandate of Section 153D, however, where draft assessment order for 123 cases were placed before the approving authority on 30.12.2017 and 31.12.2017 and the final assessment order was passed

JT. COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRLCE -1(2) , HYDERABAD vs. AMSRI BUILDERS PRIVATE LIMITED, SECUNDERABAD

In the result, assessee’s appeals are allowed and Revenue’s appeals are dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.Appeal In Ita No. Appellant Respondent A.Y 929/Hyd/2018 Amsri Builders (P) Dy.Cit 2009-10 Ltd Hyderabad Central Circle 1(2) Pan: Aaeca2834R Hyderabad - 932/Hyd/2018 Amsri Infra Projects Do - 2009-10 (P) Ltd, Secunderabad Pan:Aagca0788A 1104/Hyd/2018 Jcit (Osd) Central Amsri Builders (P) Ltd, 2009-10 Circle 1(2) Hyderabad Hyderabad Pan: Aaeca2834R 1107/Hyd/2018 -Do- Amsri Infra Projects (P) 2009-10 Ltd, Secunderabad Pan:Aagca0788A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Shri L.V Bhaskar Reddy, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 28/01/2025 घोषणा की तारीख/Pronouncement: 24/04/2025 आदेश/Order Per Vijay Pal Raothese Two Sets Of Cross Appeals(4 Appeals) Filed By Two Assessees As Well As The Revenue Are Directed Against The 2 Separate Orders Dated 12/10/2018 & 5/1/2018 Respectively Of The Learned Cit (A)-11 Hyderabad, For The A.Y.2009-10. Page 1 Of 22

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b)any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than