DY.COMMISSIONER OF INCOME TAX, CIRCLE 2(2), HYDERBAD vs. SEW INFRASTUCTURE LIMITED, HYDERABAD

reassess such income for such assessment\nyear. Further, Section 147 makes it very clear that in\norder to invoke provisions of Section 147 of the Act, there\nshould be income which has escaped assessment, and such\nescapement should be based on fresh tangible material\nwhich comes to the possession of the AO subsequent to the\ncompletion of the original assessment

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

In the result appeals filed by the Revenue\nITA

reassess such income for such assessment\nyear. Further, Section 147 makes it very clear that in\norder to invoke provisions of Section 147 of the Act, there\nshould be income which has escaped assessment, and such\nescapement should be based on fresh tangible material\nwhich comes to the possession of the AO subsequent to the\ncompletion of the original assessment

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED , HYDERABAD

reassess such income for such assessment\nyear. Further, Section 147 makes it very clear that in\norder to invoke provisions of Section 147 of the Act, there\nshould be income which has escaped assessment, and such\nescapement should be based on fresh tangible material\nwhich comes to the possession of the AO subsequent to the\ncompletion of the original assessment

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(2), HYDERABAD vs. COASTAL PROJECTS PRIVATE LIMITED , HYDERABAD

In the result, the C.O. filed by the assessee is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course

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

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

reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the assessment in the impugned assessment year was re-opened after 4 years from

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

reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the assessment in the impugned assessment year was re-opened after 4 years from

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

reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the assessment in the impugned assessment year was re-opened after 4 years from

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

reassessment or re-computation shall be made under section 147 after the expiry of nine months from the end of the financial year in which the notice under section 148 was served: Provided that where the notice under section 148 is served on or after the 1st day of April, 2019, the provisions of this sub-section shall have effect

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

reassessment or re-computation shall be made under section 147 after the expiry of nine months from the end of the financial year in which the notice under section 148 was served: Provided that where the notice under section 148 is served on or after the 1st day of April, 2019, the provisions of this sub-section shall have effect

MIR IBRAHIM ALI,USA vs. ACIT, INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

reassessment or re-computation shall be made under section 147 after the expiry of nine months from the end of the financial year in which the notice under section 148 was served: Provided that where the notice under section 148 is served on or after the 1st day of April, 2019, the provisions of this sub-section shall have effect

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1,, HYDERABAD

In the result, the appeal of assessee in ITA No

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

reassessment or re-computation shall be made under section 147 after the expiry of nine months from the end of the financial year in which the notice under section 148 was served: Provided that where the notice under section 148 is served on or after the 1st day of April, 2019, the provisions of this sub-section shall have effect

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

reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. Copy of the form for recording the reasons for initiating the proceedings under section 148 of the Act and for obtaining the approval of the JCIT

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU , HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

4. The Ld.CIT(A) failed to appreciate the fact that the provision of section 147 as well as its explanation 3 is for the benefit of the Revenue and not the assessee and is aimed at garnering the escaped income of the assessee. 5. The Id. CIT(A) failed to appreciate the fact that the Assessing Officer made addition

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

4. The Ld.CIT(A) failed to appreciate the fact that the provision of section 147 as well as its explanation 3 is for the benefit of the Revenue and not the assessee and is aimed at garnering the escaped income of the assessee. 5. The Id. CIT(A) failed to appreciate the fact that the Assessing Officer made addition

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

NALGONDA REALTORS PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee is partly allowed

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

reassessment proceedings. 6. The first issue that came up for our consideration from the assessee's appeal is the validity of re-opening of assessment under Section 147 of the Act. 7. The learned counsel for the assessee, Shri S. Rama Rao, submitted that the assessment in the impugned assessment year was re-opened after 4 years from