PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

section 271(1)(c) of the Act. Thereafter, the assessee took steps to collect the order from the A.O for filing appeal before the Ld. CIT (A) and in the meantime it received the assessment order on 08/05/2023 and filed appeal on 16/05/2023 and therefore, claimed that there is no delay in filing the appeal. 5

PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

section 271(1)(c) of the Act. Thereafter, the assessee took steps to collect the order from the A.O for filing appeal before the Ld. CIT (A) and in the meantime it received the assessment order on 08/05/2023 and filed appeal on 16/05/2023 and therefore, claimed that there is no delay in filing the appeal. 5

MAHATHI ENGINEERING INDUSTRIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, the appeal filed by the assessee is dismissed

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 263 of the Act is only an afterthought, but not a case of wrong advice or incorrect advice given by the counsel, who represent the case. Therefore, in our considered view, the reasons given by the assessee in the petition filed for condonation of delay are not sufficient to condone the huge delay of 360 days, and thus

AURORA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the assessee for the A

Bench: Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita Nos.394 & 395/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Church Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaalc0017F Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.476 & 393/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Aurora Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaata8751C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.475 & 392/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Karshak Vidya Parishad, Vs. Asstt. C. I. T. Hyderabad Central Circle 2(4) Pan:Aaatk5390B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna,Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 14/11/2024

section 139. Since there was 1036 days of delay in filing Audit Report in form 10BB by the appellant, the only recourse available with the appellant was to condonation of delay from the CCIT/DGIT(Inv) who was empowered to grant condonation of delay up to 3 years, if he is satisfied of the reasonable cause of delay. Thus, the learned

CHURCH EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the assessee for the A

Bench: Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita Nos.394 & 395/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Church Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaalc0017F Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.476 & 393/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Aurora Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaata8751C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.475 & 392/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Karshak Vidya Parishad, Vs. Asstt. C. I. T. Hyderabad Central Circle 2(4) Pan:Aaatk5390B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna,Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 14/11/2024

section 139. Since there was 1036 days of delay in filing Audit Report in form 10BB by the appellant, the only recourse available with the appellant was to condonation of delay from the CCIT/DGIT(Inv) who was empowered to grant condonation of delay up to 3 years, if he is satisfied of the reasonable cause of delay. Thus, the learned

KARSHAK VIDYA PARISHAD,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the assessee for the A

Bench: Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita Nos.394 & 395/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Church Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaalc0017F Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.476 & 393/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Aurora Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaata8751C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.475 & 392/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Karshak Vidya Parishad, Vs. Asstt. C. I. T. Hyderabad Central Circle 2(4) Pan:Aaatk5390B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna,Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 14/11/2024

section 139. Since there was 1036 days of delay in filing Audit Report in form 10BB by the appellant, the only recourse available with the appellant was to condonation of delay from the CCIT/DGIT(Inv) who was empowered to grant condonation of delay up to 3 years, if he is satisfied of the reasonable cause of delay. Thus, the learned

AURORA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the assessee for the A

Bench: Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita Nos.394 & 395/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Church Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaalc0017F Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.476 & 393/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Aurora Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaata8751C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.475 & 392/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Karshak Vidya Parishad, Vs. Asstt. C. I. T. Hyderabad Central Circle 2(4) Pan:Aaatk5390B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna,Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 14/11/2024

section 139. Since there was 1036 days of delay in filing Audit Report in form 10BB by the appellant, the only recourse available with the appellant was to condonation of delay from the CCIT/DGIT(Inv) who was empowered to grant condonation of delay up to 3 years, if he is satisfied of the reasonable cause of delay. Thus, the learned

KARSHAK VIDYA PARISHAD,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the assessee for the A

Bench: Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita Nos.394 & 395/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Church Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaalc0017F Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.476 & 393/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Aurora Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaata8751C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.475 & 392/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Karshak Vidya Parishad, Vs. Asstt. C. I. T. Hyderabad Central Circle 2(4) Pan:Aaatk5390B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna,Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 14/11/2024

section 139. Since there was 1036 days of delay in filing Audit Report in form 10BB by the appellant, the only recourse available with the appellant was to condonation of delay from the CCIT/DGIT(Inv) who was empowered to grant condonation of delay up to 3 years, if he is satisfied of the reasonable cause of delay. Thus, the learned

CHURCH EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the assessee for the A

Bench: Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita Nos.394 & 395/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Church Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaalc0017F Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.476 & 393/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Aurora Educational Vs. Asstt. C. I. T. Society, Hyderabad Central Circle 2(4) Pan:Aaata8751C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Nos.475 & 392/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2019-20 & 2020-21) Karshak Vidya Parishad, Vs. Asstt. C. I. T. Hyderabad Central Circle 2(4) Pan:Aaatk5390B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna,Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 14/11/2024

section 139. Since there was 1036 days of delay in filing Audit Report in form 10BB by the appellant, the only recourse available with the appellant was to condonation of delay from the CCIT/DGIT(Inv) who was empowered to grant condonation of delay up to 3 years, if he is satisfied of the reasonable cause of delay. Thus, the learned

BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU,KADAPA vs. DCIT, CIRCLE-1(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

5 is adequately elastic to enable the courts to apply the law in a meaningful manner which subserves the ends of justice – that being the life-purpose of the existence of the institution of courts. A justifiably liberal approach has to be adopted on principle. “Every day’s delay must be explained” does not imply a pedantic approach. The doctrine

DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD vs. BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU, YSR DIST., YSR DIST.

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

5 is adequately elastic to enable the courts to apply the law in a meaningful manner which subserves the ends of justice – that being the life-purpose of the existence of the institution of courts. A justifiably liberal approach has to be adopted on principle. “Every day’s delay must be explained” does not imply a pedantic approach. The doctrine

KUMUD BAJAJ,HYDERABAD vs. ITO, WARD-1, KHAMMAM

In the result, appeal filed by the assessee is dismissed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.782/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2016-17) Kumud Bajaj, Vs. Income Tax Officer, Hyderabad. Ward-1, Pan: Acepb3914A Khammam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Smt. S. Sandhya, Advocate राज" व "वारा/Revenue By: Shri K. Vamsi Krishna, Sr. Ar

Section 5. 9 Kumud Bajaj vs. ITO The Hon’ble SC in the case of Shiv Dass v. Union of India (UOl) and Ors., AIR 2007 SC 1330 held that the High Courts, while exercising their discretionary powers under Article 226, should consider delay or laches and, refuse to invoke its extraordinary powers if it is found that the applicant

MVR PROJECTS PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-16(4), HYDERABAD

In the result, both the appeals of the assessee are dismissed in limine

Bench: The Tribunal. The Assessee Filed Petitions For Condonation Of Delay Along With Affidavits Explaining The Reasons Contending, Inter Alia, That The Appeal Could Not Be Filed Within The Period Of Limitation Due To Miscommunication & Misguidance With The Appointed Learned Counsel Regarding The Case Proceedings To The Assessee. Further, The Appellant, Relied Entirely On The Learned Counsel & The Company'S Internal Accounting Staff For Updates & Developments, Was Under The Bona Fide Impression That The Proceedings Were Being Diligently Pursued & Attended. In Addition To That, The Part Time Accountant, Mr. Pedditi Gopal Reddy Who Was Managing The Accounts Of The Appellant'S Company & Dealt With Appointed Counsel Unfortunately Fell Gravely Ill During The Covid-19 Pandemic Period & Passed Away Which Led To A Breakdown In The Flow Of Communication Between The Assessee & Their Legal Representative. The Assessee Only

section 5 of the Limitation Act, on the expiry of the period of limitation prescribed for filing the appeal, substantive right in favour of the appellant accrues and this right should not be lightly disturbed. 7. The law of limitation is founded on public policy. It is enshrined in the legal maxim "interest reipublicae ut sit finis litium

MVR PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-16(2), HYDERABAD

In the result, both the appeals of the assessee are dismissed in limine

Bench: The Tribunal. The Assessee Filed Petitions For Condonation Of Delay Along With Affidavits Explaining The Reasons Contending, Inter Alia, That The Appeal Could Not Be Filed Within The Period Of Limitation Due To Miscommunication & Misguidance With The Appointed Learned Counsel Regarding The Case Proceedings To The Assessee. Further, The Appellant, Relied Entirely On The Learned Counsel & The Company'S Internal Accounting Staff For Updates & Developments, Was Under The Bona Fide Impression That The Proceedings Were Being Diligently Pursued & Attended. In Addition To That, The Part Time Accountant, Mr. Pedditi Gopal Reddy Who Was Managing The Accounts Of The Appellant'S Company & Dealt With Appointed Counsel Unfortunately Fell Gravely Ill During The Covid-19 Pandemic Period & Passed Away Which Led To A Breakdown In The Flow Of Communication Between The Assessee & Their Legal Representative. The Assessee Only

section 5 of the Limitation Act, on the expiry of the period of limitation prescribed for filing the appeal, substantive right in favour of the appellant accrues and this right should not be lightly disturbed. 7. The law of limitation is founded on public policy. It is enshrined in the legal maxim "interest reipublicae ut sit finis litium

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

condonation of delay before the Pr. CIT. Further, it is also held as a settled proposition of law that even if the benefit of secs.11 and 12 of the Act is denied, the gross receipt of the assessee cannot be assessed to tax without allowing the expenditure incurred by the assessee towards charitable purpose. In other words, in case

DINESH DAGA,HYDERABAD vs. ITO, WARD-5(1), HYDERABAD

In the result, appeal of the assessee is dismissed in limine

Bench: Shri Manjunatha G & Shri Ravish Sood

section 5 of the Limitation Act, that on the expiry of the period of limitation prescribed for filing the appeal, 9 ITA.No.472/Hyd./2024 substantive right in favour of the appellant accrues and this right should not be lightly disturbed. 7. The law of limitation is founded on public policy. It is enshrined in the legal maxim "interest reipublicae

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

condonation of delay before the Pr. CIT. Further, it is also held as a settled proposition of law that even if the benefit of secs.11 and 12 of the Act is denied, the gross receipt of the assessee cannot be assessed to tax without allowing the expenditure incurred by the assessee towards charitable purpose. In other words, in case

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

condonation of delay before the Pr. CIT. Further, it is also held as a settled proposition of law that even if the benefit of secs.11 and 12 of the Act is denied, the gross receipt of the assessee cannot be assessed to tax without allowing the expenditure incurred by the assessee towards charitable purpose. In other words, in case