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

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

BATTA ESHWARAMMA,R.R.DIST vs. INCOME TAX OFFICER, WARD-8(1), , HYDERABAD

In the result, all the appeals of the assessees are allowed and appeal of revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

reassess the total income taking note of the undisclosed income, if any, found during the course of search. For this purpose, the restrictions imposed on the Assessing Officer by way of sections 148 to 153 to reopen the assessment ITA.1154 & 1155/Bang/2015 Batta Yadamma and others. Page - 11 u/s 147

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

AVINASH SURYADEVARA, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(4), HYDERABAD, HYDERABAD

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

reassess the total income taking note of the undisclosed income, if any, found during the course of search. For this purpose, the restrictions imposed on the Assessing Officer by way of sections 148 to 153 to reopen the assessment ITA.1154 & 1155/Bang/2015 Page - 11 u/s 147

AVINASH SURYADEVARA, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(4), HYDERABAD, HYDERABAD

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

reassess the total income taking note of the undisclosed income, if any, found during the course of search. For this purpose, the restrictions imposed on the Assessing Officer by way of sections 148 to 153 to reopen the assessment ITA.1154 & 1155/Bang/2015 Page - 11 u/s 147

AVINASH SURYADEVARA, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-2(4), HYDERABAD, HYDERABAD

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

reassess the total income taking note of the undisclosed income, if any, found during the course of search. For this purpose, the restrictions imposed on the Assessing Officer by way of sections 148 to 153 to reopen the assessment ITA.1154 & 1155/Bang/2015 Page - 11 u/s 147

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

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

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURES LIMITED, HYD, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

reassessment, being the reasons about the escapement of some income do not exist, then it is impermissible to go ahead with the assessment u/s 147. It is sine qua non that some escaped income must be brought to charge in order to make a fresh assessment u/s 147. On the contrary, the search action itself mandates on the Assessing Officer

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

reassessment, being the reasons about the escapement of some income do not exist, then it is impermissible to go ahead with the assessment u/s 147. It is sine qua non that some escaped income must be brought to charge in order to make a fresh assessment u/s 147. On the contrary, the search action itself mandates on the Assessing Officer

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

reassessment, being the reasons about the escapement of some income do not exist, then it is impermissible to go ahead with the assessment u/s 147. It is sine qua non that some escaped income must be brought to charge in order to make a fresh assessment u/s 147. On the contrary, the search action itself mandates on the Assessing Officer

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

reassessment, being the reasons about the escapement of some income do not exist, then it is impermissible to go ahead with the assessment u/s 147. It is sine qua non that some escaped income must be brought to charge in order to make a fresh assessment u/s 147. On the contrary, the search action itself mandates on the Assessing Officer

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LIMITED, HYD, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

reassessment, being the reasons about the escapement of some income do not exist, then it is impermissible to go ahead with the assessment u/s 147. It is sine qua non that some escaped income must be brought to charge in order to make a fresh assessment u/s 147. On the contrary, the search action itself mandates on the Assessing Officer

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. MEGHA ENGINEERING & INFRASTURCTURE LTD,, HYDERABAD

In the result, all the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmans.No.

reassessment, being the reasons about the escapement of some income do not exist, then it is impermissible to go ahead with the assessment u/s 147. It is sine qua non that some escaped income must be brought to charge in order to make a fresh assessment u/s 147. On the contrary, the search action itself mandates on the Assessing Officer

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