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

u/s 142(1) of the Act dt.28.07.2009 were issued to the assessee. During the reassessment proceedings, the assessee objected to the reopening of the assessment which the AO rejected by way of passing a reasoned order. After providing due opportunity to the assessee and 4 B. Ramalinga Raju considering the partial information furnished by the assessee on 20.07.2010, along with

INCOME TAX OFFICER, WARD 3(1), HYDERABAD vs. STYPACK PRIVATE LIMITED , HYDERABAD

In the result, the appeal of the revenue is dismissed, while the cross-objection of the assessee company is allowed in terms of our aforesaid observations

Bench: Us:

90,312/- from the transaction in shares of various reputed companies on an investment of Rs.14,68,122/- 6. The AO observed that, as per the capital gains statement and the details of the stock purchased and sold by the assessee company in 5 ITA No.997/Viz/2024 & CO No.27/Hyd/2024 Stypack Private Limited respect of its transactions carried through its broker

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

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

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

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

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

u/s 143(3) of the Act. This principle has been supported by the decision of Hon'ble Supreme Court in the case of CIT Vs. Foramer France (2003) 264 ITR 566 (SC). Therefore, in our considered opinion, reopening of the assessment under Section 147 of the Act on the basis of the reasons recorded by the Assessing Officer, which

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

u/s 148, approve the same. In fact, the approving authority in discharge of his aforesaid statutory duty is obligated to record his satisfaction as regards the reasons recorded by the AO for reopening the case of the assessee, in a manner, which would reveal that as per him it is a fit case for issuance of 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

u/s 148, approve the same. In fact, the approving authority in discharge of his aforesaid statutory duty is obligated to record his satisfaction as regards the reasons recorded by the AO for reopening the case of the assessee, in a manner, which would reveal that as per him it is a fit case for issuance of 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

u/s 148, approve the same. In fact, the approving authority in discharge of his aforesaid statutory duty is obligated to record his satisfaction as regards the reasons recorded by the AO for reopening the case of the assessee, in a manner, which would reveal that as per him it is a fit case for issuance of notice u/s

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

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A 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: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

reassessment or re- computation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

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

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A 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: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

reassessment or re- computation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

SUKESINI KUMILI,HYDERABAD vs. ITO, WARD-15(1), HYDERABAD

In the result, the appeals of the assessee in ITA no

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaappeal In Ita Nos. Assessee Revenue A.Ys 1536 To 1539/ Hyd/2025 Sukesini Kumili, Hyderabad Pan:Ckmpk5466J Income Tax Officer Ward 15(1), Hyderabad 2015-16 & 2016-17 निर्धारिती द्वारा /Assessee By: Advocate Shri S. Rama Rao राजस्व द्वारा / Revenue By:: || Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: | 07/01/2016 घोषणा की तारीख / Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili ("The Assessee") Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

reassessment introduced by the CBDT. In this regards, the Ld. AR invited our attention to the order passed under section 148A(d) of the Act, dated 06.04.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both the documents clearly bear the name and designation of the JAO. It was submitted that

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

reassessment or re- computation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

SPR INFRASTRUCTURE INDIA LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-3(2), HYDERABAD, HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu(Through Virtual Hearing)

u/s 143(3), the question of change of opinion does not arise. Further, what is required at the time of issueance of notice under section 147 is reason to believe that the income has escaped assessment, but not the established act of escapement of income. In view of the judgment of Hon’ble Supreme Court, we are of the opinion

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

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

reassessment or re- computation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or, requisitioned have a bearing on the determination of the total income of such other person [for six assessment years immediately preceding the assessment year relevant to the previous

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or, requisitioned have a bearing on the determination of the total income of such other person [for six assessment years immediately preceding the assessment year relevant to the previous

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(4), HYDERABAD vs. ORBIT VENTURES, HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or, requisitioned have a bearing on the determination of the total income of such other person [for six assessment years immediately preceding the assessment year relevant to the previous

ORBIT VENTURES,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(4), HYDERABAD

In the result, the appeal of Revenue in ITA

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or, requisitioned have a bearing on the determination of the total income of such other person [for six assessment years immediately preceding the assessment year relevant to the previous