आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad (cid:302)ी रवीश सूद, माननीय Ûया(cid:467)यक सदèय एवं (cid:302)ी मधुसूदन साव(cid:875)डया, माननीय लेखा सदèय SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A. No.1591/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year:2020-21)

Prabhakar Reddy Basireddy, VS. Dy. Commissioner of Income Nalgonda. Tax, Central Circle-1(1), PAN: BCEPB2305J Hyderabad.

(अपीलाथ(cid:568)/ Appellant) ((cid:292)×यथ(cid:568)/ Respondent)

आयकरअपीलसं./I.T.A. No.1592/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2022-23)

Prabhakar Reddy Basireddy, VS. Dy. Commissioner of Income Nalgonda. Tax, Central Circle-1(1), PAN: BCEPB2305J Hyderabad.

(अपीलाथ(cid:568)/ Appellant) ((cid:292)×यथ(cid:568)/ Respondent)

: Shri PV Raghavendra Kumar, CA करदाताका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Assessee Represented by : Shri T. Venkanna, Sr. AR राजèवका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Department Represented by : 18/12/2025 सुनवाईसमाÜतहोनेक(cid:551)(cid:467)त(cid:876)थ/

Date of Conclusion of Hearing : 24/12/2025 घोषणा क(cid:551) तार(cid:547)ख/

Date of Pronouncement ORDER PER RAVISH SOOD, JM:

The captioned appeals filed by the assessee are directed against the respective orders passed by the Commissioner of Income Tax (Appeals)-11, Hyderabad, dated 23/07/2025 and 24/07/2025, which in turn arises from the respective orders passed by the AO under section 147 of the Income Tax Act, 1961 (for short, “the Act”) for AY 2020-21 and AY 2022-23. As a common issue is involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. We shall first take up the appeal for the AY 2020-21 in ITA No.1591/Hyd/2025, and the order therein passed shall apply mutatis mutandis for the purpose of disposing of the other appeal. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

“1. The order of the learned Commissioner of Income Tax (Appeals)-11, Hyderabad, is not correct either on facts or in law, and is therefore liable to be set aside.

2. In the facts and circumstances of the case, the learned CIT(A) erred in upholding the validity of reassessment proceedings initiated under section 147 of the IT Act, without appreciating that the very notice issued under section 148 is bad in law and void ab initio.

3. The Ld. CIT(A) is not justified in sustaining the reopening without (a) any incriminating material relating to AY 2020-21 found in the search on 04.01.2023, and (b) appreciating the fact that the notice u/s 148 was based only on deemed information under Explanation 2(1) and not on any evidence of income escaping assessment, thereby making the reassessment invalid and without jurisdiction.

4. The Ld. CIT(A) is not justified in sustaining the assessment without appreciating that the Assessing Officer did not furnish the recorded reasons for reopening despite specific request, thereby making the reassessment void as being in violation of law and against principles of natural justice.

5. The learned CIT(A) is not justified in sustaining the addition of Rs 3,79,605 by estimating profit at 20% of sheep sales turnover of Rs 18,98,023, without appreciating that the appellant had actually incurred a loss in the said activity due to livestock deaths and maintenance expenses.

6. The appellant craves leave to add, amend, alter, or withdraw any of the above grounds at the time of hearing.”

Apart from that, the assessee has raised the following additional ground of appeal before us:

“Since the notice u/s 148 was issued by the JAO, ACIT Central Circle- 1(1), Hyderabad and not in a faceless manner, the said notice is invalid and all further proceedings are equally bad in law.”

As the assessee appellant, by raising the aforesaid additional ground of appeal, has sought our indulgence for adjudicating a purely legal issue which