आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad (cid:302)ी (cid:874)वजय पाल राव, उपाÚ य¢ एव ं (cid:302)ी मंजुनाथ जी, लेखा सदè य के सम¢ ।

Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha G. Accountant Member आ.अपी.सं /ITA Nos.1566 and 1571/Hyd/2025 (िनधा१रण वष१/Assessment Years: 2020-21 and 2021-22)

M/s. EXEL Rubber Private Ltd Vs. Dy.CIT Hyderabad Central Circle 1 (2) PAN:AAACE4495J Hyderabad (Appellant) (Respondent)

िनधा१ौरती (cid:554)ारा/Assessee by: Shri M.V. Prasad, CA राज(cid:830) व (cid:554)ा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.

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 and 2022-23 respectively. Since common issues are involved in these two appeals, for the sake of convenience, these were heard together and are being disposed of by this common consolidated order.

ITA No.1566/Hyd/2025 A.Y 2020-21

2. The assessee has raised the following grounds of appeal:

“1. On the facts and circumstance of the case, Learned CIT(A)

erred in passing the order both on law and facts.

2. On the facts and circumstance of the case, the Learned CIT(A) is not justified in dismissing the ground that the issue of notice U/s 148 by the Assessing Officer is without Jurisdiction.

3. On the facts and circumstance of the case, the Learned CIT(A) is not justified in dismissing the ground that issue of notice U/s 148 by the Assessing Officer is bad in law as the Assessing Officer has not fulfilled the prescribed conditions laid down under Section 148 and consequently the Assessment is void-abinitio.

4. On the facts and circumstance of the case, the learned CIT(A) is not justified in dismissing the ground that ‘the addition of Rs.62,16,740/- made by the Assessing Officer and further there is no corroborative evidence to prove that expenditure is bogus.

5. Any other legal and factual ground or grounds that may be urged at the time of hearing of the appeal.”

3. The brief facts of the case are that the assessee company filed the return of income for the A.Y 2020-21 on 12.02.2021, admitting total Income of Rs.103,29,39,000/-. The case was selected for scrutiny and assessment u/s. 143(3) r.w.s. 144B of the Act was completed on 23.09.2022 accepting the returned income. A Search and Seizure operation u/s.132 of the I.T. Act was carried out on 04.01.2023 in M/s Exel Rubber Group of entities. As a part of the search, the case of the assessee was covered u/s 132 of the I.T. Act. A search & seizure operation under section 132 of the Act, was carried on 4/1/2023 in Exel Group of companies and as a part of search, the case of the assessee was also covered under section 132 of the Act.

Simultaneous search proceedings were also conducted in the residential premises of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager who looks after the financial and accounting matters of Exel Group of companies. During the course of search, in the residential premises of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager, certain loose sheets, promissory notes and excel sheets and a DELL Laptop were found and seized. On verification of the laptop, it was found that there was a software called FOCUS 5.5 software loaded in the laptop and some excel workbook containing the details of several hundreds of transactions representing receipts and payments in cash were found and recorded for several financial years. The incriminating material found during the course of search were confronted to Shri Ramesh Kumar Sanaka, Sr. Accounts Manager and a statement under section 132(4) of the Act has been recorded. In his statement, of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager explained that the transactions recorded in the FOCUS 5.5 software a