आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G. ACCOUNTANT MEMBER 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)

िनधा१ौरती (cid:554)ारा /Assessee by: CA M V Prasad राज(cid:830) व (cid:554)ा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 PER BENCH:

The above six appeals filed by the Assessee viz., Vilas Polymer Private Limited are directed against the separate Orders dated 29.10.2025 and 30.10.2025, of the learned CIT(A), Hyderabad-11, Hyderabad, arising from the assessment order passed u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961, pursuant to the search & seizure operations u/s 132 of the Act, dated 04/01/2023, in case of Excel Group of Companies including the assessee for the A.Ys 2014-15 to 2019-20 respectively. Since common issues are raised in this group of six appeals arising from same facts and search and seizure operation, therefore, for the sake of convenience, all these six appeals ITA Nos.1870 to 1875/Hyd./2025 in the case of Vilas Polymer Private Limited were clubbed together for the purpose of hearing and adjudication. For the purpose of recording the facts, the appeal in ITA No.1870/Hyd/2025 for the A.Y 2014-15 is taken as “lead” case.

2. The assessee has raised identical grounds for all these six assessment years, except some extra grounds raised for the assessment year 2019-2020. The grounds of appeal in ITA No.1870/Hyd/2025 are reproduced as under:

1. “On the facts and circumstances of the case, the Learned CIT(A) erred in both law and facts while passing the Order.

2. On the facts and circumstance of the case, 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 circumstances of the case, Learned CIT(A) is not justified in dismissing the ground that the 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 circumstances of the case, Learned CIT(A) is not justified in dismissing the ground that the notice issued U/s 148 and consequent Assessment is in valid in law as the Assessing Officer has not complied the provisions of Section

149 of the Income Tax Act.

5. On the facts and circumstances of the case, Learned CIT(A)

erred in dismissing the legal grounds.

6. On the facts and circumstance of the case that the Assessment Order Passed U/s 143(3) read with Section 148 is vitiated and has become unsustainable in law since the approval U/s 1488 has been accorded by Addl CIT/JCIT(Range head in a mechanical manner.

7. On the facts and circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned notice under Section 148 is bad in law.

8. On the facts and circumstance of the case, Learned CIT(A) is not justified in sustaining the addition of Rs.2,48,50,183/-.

9. On the facts and circumstance of the case, Learned CIT(A) is not justified in sustaining the addition of Rs.1,45,55,125/-

10. Any other ground or grounds that may be urged at the time of hearing of the appeal.”

3. Facts of the case in brief are that, the assessee company is part of Excel group, was subjected to search & seizure action on 04.01.2023. The group consists of M/s Excel Rubber Private Limited, M/s Ace Tyres Private Limited and M/s Vilas