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

ITA 2172/HYD/2025Status: DisposedITAT Hyderabad25 February 2026AY 2021-22Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha G. (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the seized material did not conclusively prove violations of Section 269ST, as it lacked transaction-wise and buyer-wise details. Admission of additional income alone is not sufficient for penalty without corroborative evidence.

What were the facts?

During a search, unaccounted cash receipts from the sale of spent solvents and scrap were found. The assessee admitted additional income, but the AO initiated penalty proceedings under Section 271DA for alleged violation of Section 269ST.

What were the issues?

Whether penalty under Section 271DA for violation of Section 269ST can be levied solely based on admitted additional income without specific evidence of transaction-wise violations?

Which sections of the Income-tax Act were involved?

Section 132,Section 153A,Section 269ST,Section 271DA,Section 274,Section 275(1)(c)

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Cases cited in this judgment(9)Show list

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

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

Hearing: 21/01/2026

Per. MANJUNATHA, G. A.M.

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 common consolidated

The order continues below.

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