INCOME TAX OFFICER, WARD-1, WARANGAL vs. SHIVA KUMAR THOTA, WARANGAL

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

148A(d) of the Act, dated 29/07/2022 was passed by the AO. Thereafter, the AO issued notice under section 148 of the Act, dated 29/07/2022. 5. The AO thereafter vide his order passed under section 147 r.w.s 144B of the Act, dated 26/05/2023 assessed the income of the assessee at Rs.8,15,30,754/- after making certain additions

KILARU VENKATA SATISH,KRISHNA DIST vs. DCIT, CENTRAL CIRCLE-1(3), HYDERABAD

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

Bench: Us), Which Reads As Under:

148A(d) of the Act, dated 11/04/2022 was passed by the Jurisdictional Assessing Officer (“JAO”). 5. Thereafter, the AO in absence of any material placed on record by the assessee to substantiate the creditworthiness and genuineness of the loan transaction of Rs.50 lakhs held the same as an unexplained cash credit under section 68

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

The appeal of the Assessee is allowed on this ground alone

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 - the period of two weeks -is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

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:

Section 147 r.w.s.144B of the Income Tax Act, 1961 (for short “the Act”) dated 21.03.2024 for A.Y. 2018-19. The revenue has assailed the impugned order on the following grounds of appeal before us: 3 ITA No.997/Viz/2024 & CO No.27/Hyd/2024 Stypack Private Limited 2. Apart from that, the assessee company is before us as a cross- objector on the following

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

148A(d) AND/OR issuance of notice under section 148 of Name: RAJAT BANSAL the Income-tax Act, 1961? Designation: PCCIT, DELHI Date: 20/03/2023 15. It is evident that the approval order is bereft of any reasons. It does not even refer to any material that may have weighed in the grant of approval. The mere appending of the word

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

148A(d) AND/OR issuance of notice under section 148 of Name: RAJAT BANSAL the Income-tax Act, 1961? Designation: PCCIT, DELHI Date: 20/03/2023 15. It is evident that the approval order is bereft of any reasons. It does not even refer to any material that may have weighed in the grant of approval. The mere appending of the word

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

148A(d) AND/OR issuance of notice under section 148 of Name: RAJAT BANSAL the Income-tax Act, 1961? Designation: PCCIT, DELHI Date: 20/03/2023 15. It is evident that the approval order is bereft of any reasons. It does not even refer to any material that may have weighed in the grant of approval. The mere appending of the word

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:

148A(d) AND/OR issuance of notice under Name: Rajat Bhansal section 148 of the Income- tax Act, 1961? Designatgion PCCIT Delhi Date: 20/0-3/2023 15. It is evident that the approval order is bereft of any reasons. It does not even refer to any material that may have weighed in the grant of approval. The mere appending of the word

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

section 147 of the Act by issuing the notice under section 148 of the Act is quashed. Since we have decided the legal issue in favour of the assessee therefore no finding is given on the other grounds raised by the assessee on merit." Also, we find that a similar view had been taken by the ITAT, Chandigarh

VENKATA RAMA KRISHNAM RAJU CHINTALAPATI,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

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

Bench: Us.

148A of the Act. Notice under section 148 of the Act, dated 31.03.2023, was issued by the AO. In response, the assessee filed his return of income, declaring an income of Rs. 7,98,890/-. 3. Thereafter, the AO, vide his order passed u/s 147 r.w.s. 144B of the Act, due to the failure of the assessee to comply

DILEEP KUMAR SAKAMURI CHENCHU VENKATA,SRIKALAHASTI vs. INCOME-TAX OFFICER, WARD-1(3), TIRUPATI

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

Bench: Us:

68,428 under the head "income from other sources" 4. That on the facts and circumstances of the case, the Ld.AO/NFAC/CIT(A) erred in levying interest under Section 23B and Section 234C of the Act Additional Grounds being raised before the Hon'ble ITAT for the first time 5. That on the facts and circumstances of the case

RAMESH SISTLA,HYDERABAD vs. ITO., WARD-14(1), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

148A(d) of the Act on the same date. In response to the said notice issued under section 148 of the Act, the assessee filed a return of income on 17.05.2022 declaring total income of Rs.8,540/-. During the course of assessment proceedings, the assessee partially complied with the notices issued under section

CHINTHALAPUDI RAMAKRISHNA,KHAMMAM vs. ITO., WARD-1, KOTHAGUDEM

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

148A(d) on 25.04.2022, the Ld. AO issued notice under section 148 of the Act on 26.04.2022. In response, the assessee filed his return of income on 13.05.2022 declaring a total income of Rs.2,93,100/-. During the reassessment proceedings, the Ld. AO found that the assessee had deposited cash of ITA No.473/Hyd/2025 4 Rs.136,68

SUDHA DOSHI,HYDERABAD vs. ITO - WARD 5(1), HYDERABAD

148A(d) of the Act, dated 30/07/2022. Accordingly, notice under section 148 of the Act, dated 30/07/2022 was issued and served upon the assessee calling upon her to file the return of income in compliance thereto. 6. Ostensibly, the assessee initially did not file her return of income within the time period prescribed in the notice issued under section

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

148A(b) is far less than what is required to be submitted to counter the issues mentioned in the notice, the assessee can use the reassessment proceedings to validate his claim by producing relevant corroborative evidences required rather than requesting to drop the proposals to reopen under section 148 of LT Act by stating that there is no Income

ABRAHAM NATHANIEL ADDANKI,HYDERABAD vs. ITO., WARD-14(1), HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1148/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Abraham Nathaniel Vs. Income Tax Officer, Addanki, Ward-14(1), Hyderabad. Hyderabad. Pan: Adqpa7546N

68,00,508/- along with agricultural income of Rs.72,500/-. 9. Aggrieved, the assessee carried the matter in appeal before the CIT(A). As the assessee, despite having been afforded 4 opportunities, had failed to participate in the proceedings before the CIT(A), therefore, the latter holding a conviction that the assessee was not interested in prosecuting the appeal, dismissed

POREDDY SAMBASIVA REDDY,KADIRI vs. ITO, WARD-1, HINDUPUR

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1862/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2018-19) Poreddy Sambasiva Reddy, Vs. Income Tax Officer, Kadiri. Ward-1, Pan: Bibpr4972G Hindupur. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Nvv Gopalal Krishna, Ca Assessee Represented By राज"वका""त"न"ध"व/ : Dr. Sachin Kumar, Sr.Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 09/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 13/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Poreddy Sambasiva Reddy, Kadiri (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 22/10/2025 For The Assessment Year (“A.Y.” 2018-19. Poreddy Sambasiva Reddy Vs. Ito 2. The Assessee Has Raised The Following Grounds Of Appeal:

148A(d) of the Act on 02.04.2022 holding that it was a fit case for issuance of notice under section 148 of the Act and consequently issued notice under section 148 of the Act on 03.04.2022. During the reassessment proceedings, the assessee neither filed the return of income in response to the notice issued under section

ACIT., CIRCLE-8(1), HYDERABAD vs. RAJIV GUPTA, HYDERABAD

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.278/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Assistant Commissioner Of Vs. Rajiv Gupta, Income Tax, Hyderabad. Cirle-8(1), Hyderabad. Pan: Acapg4029K (Appellant) (Respondent)

68 of the Act. Apart from that, the AO held a conviction that the assessee 3 ACIT vs. Rajiv Gupta would have incurred commission charges for availing the aforementioned accommodation entry and made a further addition of Rs.59,185/- on account of unexplained expenditure that would have been incurred towards commission charges under section 69C of the Act. Accordingly

PRAKASH KANYADARA,VIJAYAWADA vs. INCOME TAX OFFICER (INT TAXN)-1, HYDERABAD

In the result, appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

148A(a) of the Act on 31/05/2022 by furnishing the information and material which was relied upon. 5. In response to such notice, assessee submitted that he is a non- resident and employed in USA and during the year, he earned rental P a g e 2 | 8 income in India from immovable property of Rs. 1.22 lakhs and interest