THE PRUDENTIAL CO-OPERATIVE URBAN BANK LIMITED,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

reassessment u/s 147, there must be some failure on the part of the asessee to disclose fully and truly all material facts necessary for the assessment already had been done in previous occasion. However explanation-I to section 147 of the Act states that the production before the Assessing Officer of account books or other evidence from which material evidence

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

40. In the context of the above provisions of section 149(1)(b) of the Act vis-a- vis notice u/s 148 of the Act, it was submitted by learned Counsel that provisions of section 149(1)(b) of the Act, empowers an authority to issue notice u/s 148 of the Act, if the alleged income is represented

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

40,000 5 Smt. B. Suryanarayana 1,22,81,000 6 Smt. B. Radha 1,14,04,000 7 Sri B. Teja Raju 78,94,500 8 Sri B. Rama Raju (Jr.) 78,94,500 Total 10,03,00,000 18 B. Ramalinga Raju 7.2 During the course of reassessment proceedings, the assessee was directed to furnish the details

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

40,000 5 Smt. B. Suryanarayana 1,22,81,000 6 Smt. B. Radha 1,14,04,000 7 Sri B. Teja Raju 78,94,500 8 Sri B. Rama Raju (Jr.) 78,94,500 Total 10,03,00,000 18 B. Ramalinga Raju 7.2 During the course of reassessment proceedings, the assessee was directed to furnish the details

PITTI HOLDINGS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

Section 147 has this effect that the Assessing Officer has to assessee or reassess the income (""such income"") which escaped assessment and which was the basis of the formation of belief and if he does so, he can also assess or reassess any other income which has escaped assessment and which comes to his notice during the course

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-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, 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, 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

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

40. In the context of the above provisions of section 149(1)(b) of the Act vis-a- vis notice u/s 148 of the Act, it was submitted by learned Counsel that provisions of section 149(1)(b) of the Act, empowers an authority to issue notice u/s 148 of the Act, if the alleged income is represented

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

40. In the context of the above provisions of section 149(1)(b) of the Act vis-a- vis notice u/s 148 of the Act, it was submitted by learned Counsel that provisions of section 149(1)(b) of the Act, empowers an authority to issue notice u/s 148 of the Act, if the alleged income is represented

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

40. In the context of the above provisions of section 149(1)(b) of the Act vis-a- vis notice u/s 148 of the Act, it was submitted by learned Counsel that provisions of section 149(1)(b) of the Act, empowers an authority to issue notice u/s 148 of the Act, if the alleged income is represented

SURENDER KUMAR BHOJWANI,HYDERABAD vs. ITO, INTL. TAXTION -1, HYDERABAD

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

40. It would be seen that whereas in the case of Anglo French Textile Co. Ltd. (supra) the question as to the rights of an assessee to claim 'redoing', 'revising' or 'recomputing' entire income during the reassessment proceedings was left open, that question did not come up for consideration in the case of H.R. Shri Ramulu ( supra) or H.M. Esufali

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:

40. In the context of the above provisions of section 149(1)(b) of the Act vis-a- vis notice u/s 148 of the Act, it was submitted by learned Counsel that provisions of section 149(1)(b) of the Act, empowers an authority to issue notice u/s 148 of the Act, if the alleged income is represented

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

40 ITA.No.1527 & 1528/Hyd./2025 Act dated 27.07.2022 by obtaining prior approval from the Commissioner of Income Tax [International Taxation]- 2, Mumbai dated 25.07.2022 is not in accordance with sec.151(ii) of the Income Tax Act, 1961 as applicable from 01.04.2021 onwards. Therefore, we quash the notice issued u/sec.148 of the Act dated 01.04.2021 and 27.07.2022 and consequent Final Assessment

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

reassessment proceedings under section 147 of the Act. b) No evidence of any new tangible material has been referred to by the Ld. AO in the reasons for re-opening the assessment and hence, it is a mere change of opinion, and the Ld. AO does not have any reason to believe that income has escaped assessment. c) There

PRYSMIAN CAVI E SISTEMI S.R.L,HYDERABAD vs. DCIT (INT,TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

reassessment order dated 20.12.2006 under\nsection 143(3) r.w.s. 147 of the Act was adjudicated separately by the Tribunal\nvide order dated 30.11.2015. In that order, the Tribunal directed the Assessing\nOfficer to delete the addition made in respect of offshore contract receipts;\nestimate the income at 10% of the onshore contract works / services receipts;\nand specifically directed

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

147 of the Act dated 28-12- 2019 is invalid and liable to be quashed. Thus, we quash the assessment order passed by the AO. 25. The other issues that came up for our consideration from ground nos. 4 to 8 of assessee’s appeal are relating to the addition of Rs.41,64,131/- towards finance cost being interest paid