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

undisclosed income for the assessment year 2002-03." 8.2 From the above facts, it is clear that a total amount of $9.76 Million (with an average exchange then prevailing rate of Rs.47/-) equaling to Rs.45,87,20,000/- was unaccountedreceipt in the hands of Sri B. Ramalinga Raju during the Financial Year 2001-02 relevant

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

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 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

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:

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

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material is not sustainable in law. The Hon'ble Supreme Court in case of PCIT vs. Abhisar Buildwell (P) Ltd (Supra) has held in Para 10 to 14 as under: “10. On a plain reading of Section 153A of the Act, 1961, it is evident that once

ACIT CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material is not sustainable in law. The Hon'ble Supreme Court in case of PCIT vs. Abhisar Buildwell (P) Ltd (Supra) has held in Para 10 to 14 as under: “10. On a plain reading of Section 153A of the Act, 1961, it is evident that once

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

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material is not sustainable in law. The Hon'ble Supreme Court in case of PCIT vs. Abhisar Buildwell (P) Ltd (Supra) has held in Para 10 to 14 as under: “10. On a plain reading of Section 153A of the Act, 1961, it is evident that once

MADHUCON PROJECTS LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material is not sustainable in law. The Hon'ble Supreme Court in case of PCIT vs. Abhisar Buildwell (P) Ltd (Supra) has held in Para 10 to 14 as under: “10. On a plain reading of Section 153A of the Act, 1961, it is evident that once

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

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material is not sustainable in law. The Hon'ble Supreme Court in case of PCIT vs. Abhisar Buildwell (P) Ltd (Supra) has held in Para 10 to 14 as under: “10. On a plain reading of Section 153A of the Act, 1961, it is evident that once

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

u/s 80IA of the I.T. Act, 1961 in the absence of any incriminating material is not sustainable in law. The Hon'ble Supreme Court in case of PCIT vs. Abhisar Buildwell (P) Ltd (Supra) has held in Para 10 to 14 as under: “10. On a plain reading of Section 153A of the Act, 1961, it is evident that once

RAIL ROAD CONSTRUCTIONS PRIVATE LIMITED ,ORISSA vs. DEPUTY COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-1(3), HYDERABAD

In the result, both the appeals of the assessee are allowed in above terms

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment of total income under the provisions of 132 r.w.s 153A of the Act. Similar position will obtain in a case where undisclosed income or undisclosed property has been found as a consequence of search. In other words, harmonious interpretation will be that the assessment will be made on the basis of other documents or deeds not found or produced

RAIL ROAD CONSTRUCTIONS PRIVATE LIMITED ,ORISSA vs. DEPUTY COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-1(3), HYDERABAD

In the result, both the appeals of the assessee are allowed in above terms

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

reassessment of total income under the provisions of 132 r.w.s 153A of the Act. Similar position will obtain in a case where undisclosed income or undisclosed property has been found as a consequence of search. In other words, harmonious interpretation will be that the assessment will be made on the basis of other documents or deeds not found or produced

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, (f, 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, (f, 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