करदाता का प्रतततितित्व/ Assessee Represented by : Shri M.V. Prasad, C.A. and Mr. K.S. Rajendra Kumar (I.R.S. Retd.)

राजस्व का प्रतततितित्व/ Department Represented by : Dr. Narendra Kumar Naik – CIT-DR & Dr. Sachin Kumar – Sr. A.R.

सुिवाई समाप्त होिेकी ततति/ Date of Conclusion of Hearing : 22.04.2026

घोषणा की तारीख/ Date of Pronouncement : 30.04.2026

O R D E R

PER MANJUNATHA G., A.M :

The captioned appeals filed by the assessee and the Revenue are directed against separate, but identical orders of the learned Commissioner of Income Tax (Appeals) – 11, Hyderabad, dated 08.12.2025 and 09.12.2025, pertaining to the assessment years 2020–21 and 2022–23, respectively. Since the facts are identical and common issues are involved in all these appeals, the same were heard together and are being disposed of by this single consolidated order for the sake of convenience and brevity.

The assessee and the Revenue have more or less raised common grounds of appeal in all their respective captioned appeals. Therefore, for the sake of brevity, the grounds of appeal filed by the assessee (Bharath Kumar Kondareddy) in ITA No.310/Hyd/2025 for the assessment year 2020–21 and the grounds of appeal filed by the Revenue in ITA No.940/Hyd/2026 for the assessment year 2021–22 are reproduced as under:

“1. The order of the Ld. CIT(Appeals) is erroneous on the facts of the case and contrary to the provisions of law.

2. On the facts and circumstances of the case and in law, the assessment order passed u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961 is void ab initio, as the reassessment proceedings initiated by issue of notice u/s 148 without due compliance with the requirements of sections 148 and 148A is without jurisdiction and unsustainable in law.

3. On the facts and circumstances of the case and in law, the assessment order passed u/s 143(3) r.w.s. 147 of the Act is void ab initio, as the prior approval for issue of notice u/s 148 was accorded by the specified authority u/s 151 in a mechanical manner without proper application of mind.

4. On the facts and circumstances of the case and in law, the assessment order passed u/s 143(3) r.w.s. 147 is unsustainable in law, since the approval under section 148A has been accorded by the Range Head in a mechanical manner without proper application of mind.

5. On the facts and circumstances of the case and in law, the Ld. CIT(A) is not justified in sustaining the addition of unexplained money of Rs.12,00,00,000/- under section 69A of the Act towards alleged on-money payment for purchase of commercial space in Jyothi Tech Park from M/s. Vamsiram Builders.

6. The Ld. CIT(A) ought to have held that the addition made by relying solely on the notings in the material found during the search carried out in the case of a third party (Vamsiram Group), which are neither in the handwriting of the appellant nor bear the signature of the appellant and which are not corroborated by any independent evidence, is not sustainable in law.

7. The Ld. CIT(A) ought to have appreciated that no evidence to corroborate the notings in the material found during the search carried out in the case of a third party was found during the simultaneous search carried out at the residential premises of the appellant.

8. The Ld. CIT(A) erred in failing to appreciate that there is no material or evidence on record to show that the notings in the seized material have materialised into transactions giving rise to undisclosed income of the appellant.

9. The