SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

section 153D of the Act. There are three or four\nrequirements that are mandated therein, (i) the Assessing Officer\nshould submit the draft assessment order \"well in time\". Here it was\nsubmitted just two days prior to the deadline thereby putting the\napproving authority under great pressure and not giving him sufficient\ntime to apply his mind

SYED WARISUDDIN NAVEED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

In the result, the remaining appeals filed by the assessees (at Sl

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

RAGHUNATH REDDY GANGARAM,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2),, HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

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

In the result, the remaining appeals filed by the assessees (at Sl

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

MADHAVA REDDY BADDEVOLU,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

ACE TYRES PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

SYED WARISUDDIN NAVEED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the remaining appeals filed by the assessees (at Sl

68,000/- under Section 115BBE of the Act. 8. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tribunal. 9. The learned counsel for the assessee, Shri M. V. Prasad, C.A., referring to petition filed by the assessee for admission of additional ground, submitted that, the assessee has taken a legal ground

LEKCON INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(2), HYDERABAD

153D in respect of proposed\nassessment order by the A.C.I.T., Central Circle-3(2), Hyderabad.\n12. Ld. A.O. and Ld. CIT(A) failed to appreciate that the WhatsApp chats\ndo not constitute valid evidence without a certificate under Section 65B of\nthe Indian Evidence Act, 1872.\n13. Ld. A.O. erred in invoking the provisions of Section 115BBE

PURUSHOTHAM NAIDU LEKKALA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(2), HYDERABAD, HYDERABAD

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

153D in respect of proposed\nassessment order by the A.C.I.T., Central Circle-3(2), Hyderabad.\n12. Ld. A.O. and Ld. CIT(A) failed to appreciate that the WhatsApp chats\ndo not constitute valid evidence without a certificate under Section 65B of\nthe Indian Evidence Act, 1872.\n13. Ld. A.O. erred in invoking the provisions of Section 115BBE

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE 3(4), HYDERABAD vs. ZAINAB INVESTMENTS PRIVATE LIMITED , HYDERABAD

68 of the Act. Although the Assessing Officer\nreferred to number of judicial precedents, including the decision of\nHon'ble Supreme Court in the case of PCIT Vs. NRA Iron and Steel\nPrivate Ltd. (2019) 412 ITR 161, but facts remain that the facts of\nthe present case are entirely different from various case laws\nreferred by the Assessing Officer

ASSIATANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE 3(4), HYDERABAD vs. ZAINAB INVESTMENTS PRIVATE LIMITED , HYDERABAD

In the result, appeals filed by the Revenue and the assessee for the A

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.66/Hyd/2021 To 69/Hyd/2021 (निर्धारण वर्ा/A.Y: 2011-12, 2013-14, 2015-16 & 2016-17) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.70/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.111/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) M/S Zainab Investments Vs. Asst.Commissioner Of Income Tax Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 20/02/2025 Pronouncement:

68 of the Act as unexplained cash credit. The Ld.CIT(A), after considering relevant facts has rightly deleted the additions made by the Assessing Officer. Therefore, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal filed by the Revenue. 49. In the result, appeal filed by the Revenue is dismissed. ITA No.70/Hyd/2021, A.Y.2018-19

ASSISTANT COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE 3(4), HYDERABAD vs. ZAINAB INVESTMENTS PRIVATE LIMITED , HYDERABAD

In the result, appeals filed by the Revenue and the assessee for the A

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.66/Hyd/2021 To 69/Hyd/2021 (निर्धारण वर्ा/A.Y: 2011-12, 2013-14, 2015-16 & 2016-17) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.70/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.111/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) M/S Zainab Investments Vs. Asst.Commissioner Of Income Tax Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 20/02/2025 Pronouncement:

68 of the Act as unexplained cash credit. The Ld.CIT(A), after considering relevant facts has rightly deleted the additions made by the Assessing Officer. Therefore, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal filed by the Revenue. 49. In the result, appeal filed by the Revenue is dismissed. ITA No.70/Hyd/2021, A.Y.2018-19

ASSIATANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-3(4), HYDERABAD vs. ZAINAB INVESTMENTS PRIVATE LIMITED , HYDERABAD

In the result, appeals filed by the Revenue and the assessee for the A

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.66/Hyd/2021 To 69/Hyd/2021 (निर्धारण वर्ा/A.Y: 2011-12, 2013-14, 2015-16 & 2016-17) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.70/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.111/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) M/S Zainab Investments Vs. Asst.Commissioner Of Income Tax Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 20/02/2025 Pronouncement:

68 of the Act as unexplained cash credit. The Ld.CIT(A), after considering relevant facts has rightly deleted the additions made by the Assessing Officer. Therefore, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal filed by the Revenue. 49. In the result, appeal filed by the Revenue is dismissed. ITA No.70/Hyd/2021, A.Y.2018-19

ZAINAB INVESTMENTS PRIVATE LIMITED ,SECUNDERABAD,SECUNDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE -3(4),HYDERABAD, HYDERABAD

In the result, appeals filed by the Revenue and the assessee for the A

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.66/Hyd/2021 To 69/Hyd/2021 (निर्धारण वर्ा/A.Y: 2011-12, 2013-14, 2015-16 & 2016-17) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.70/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) Asst.Commissioner Of Vs. M/S Zainab Income Tax Investments Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) आ.अपी.सं /Ita No.111/Hyd/2021 (निर्धारण वर्ा/A.Y: 2018-19) M/S Zainab Investments Vs. Asst.Commissioner Of Income Tax Pvt. Ltd. Central Circle-3(4) Secunderabad Hyderabad [Pan : Aaacz4043R] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 20/02/2025 Pronouncement:

68 of the Act as unexplained cash credit. The Ld.CIT(A), after considering relevant facts has rightly deleted the additions made by the Assessing Officer. Therefore, we are inclined to uphold the order of the Ld.CIT(A) and dismiss the appeal filed by the Revenue. 49. In the result, appeal filed by the Revenue is dismissed. ITA No.70/Hyd/2021, A.Y.2018-19

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), HYDERABAD vs. TUMU RAJKUMAR , HYDERABAD

In the result, all the appeals filed by the Revenue are allowed for statistical purposes and the C

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

section 153D has not prohibited passing of the consolidated order of approval. In the light of the above, the additional ground raised by the assessee is devoid of merit. The decision relied upon by the assessee in the case of Sanjay Duggal (supra) is not applicable to the facts of the present case as the approval was granted