MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL CIT, CENTRAL RANGE-2, HYDERABAD

ITA 2164/HYD/2025Status: DisposedITAT Hyderabad25 February 2026AY 2018-1933 pages
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What did the Tribunal hold?

The Tribunal held that the penalty order was barred by limitation as it was passed beyond the time prescribed under Section 275(1)(c) of the Income Tax Act. The Tribunal also noted that the assessee's contention regarding the burden of proof and lack of evidence for violation of Section 269ST was valid.

What were the facts?

During a search, unaccounted cash from the sale of spent solvents was found. The assessee admitted additional income, but argued that this did not automatically mean a violation of Section 269ST. The Assessing Officer initiated penalty proceedings under Section 271DA for alleged violations of Section 269ST.

What were the issues?

Whether the penalty order under Section 271DA was passed within the limitation period prescribed by Section 275(1)(c)? Whether the admission of additional income automatically implies a violation of Section 269ST?

Which sections of the Income-tax Act were involved?

Section 271DA,Section 269ST,Section 275(1)(c),Section 132,Section 153A

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Cases cited in this judgment(6)Show list

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Income Tax Appellate Tribunal, Hyderabad ‘B‘Bench, Hyderabad

Before: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri M.V. Prasad, CA
For Respondent: Dr. Sachin Kumar, Sr. AR
Hearing: 21/01/2026

These four appeals filed by the assessee are directed against the separate, but identical orders passed by the Learned Commissioner of Income Tax (Appeals)-12, Hyderabad, all dated 08/10/2025 for the A.Ys 2018-19 to 2021-22 respectively. Since, identical issues have been raised by the assessee in all these four appeals, for the sake of convenience, these appeals were heard together and are being disposed off, by this co

The order continues below.

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