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. After receiving the penalty order, the assessee took steps to collect the order from the A.O and finally able to receive the assessment order on 8/5/2023 and filed an appeal before the Ld. CIT (A) on 16/05/2023. If we consider the above date, there is no delay in filing the appeal. However

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. After receiving the penalty order, the assessee took steps to collect the order from the A.O and finally able to receive the assessment order on 8/5/2023 and filed an appeal before the Ld. CIT (A) on 16/05/2023. If we consider the above date, there is no delay in filing the appeal. However

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)

condoning the delay, the other grounds taken by the assessee, including challenging the validity of the order passed by the Ld. Pr. CIT under Section 263 of the Act, become academic in nature, and thus, the same are dismissed as ‘infructuous’. 17 Mahati Engineering Industries Private Limited 13. In the result, the appeal filed by the assessee is dismissed. Order

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

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

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

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

9. We have heard the rival submissions and carefully perused the materials on record. From the facts of the case it is apparent that the Ld. CIT (A) has not appreciated the adverse situation faced by the assessee but proceeded to adjudicate the matter prejudiced by the conduct of the assessee before the Ld. AO for non-appearance

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

9. We have heard the rival submissions and carefully perused the materials on record. From the facts of the case it is apparent that the Ld. CIT (A) has not appreciated the adverse situation faced by the assessee but proceeded to adjudicate the matter prejudiced by the conduct of the assessee before the Ld. AO for non-appearance

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

9. The learned CIT(A) ought to have considered that several Judicial rulings and Circulars of the CBDT state that minor filing delays should not deny tax exemptions. 10. The Ld. CIT(A) ought to have appreciated that the assessee trust has satisfied conditions for claiming exemption for past many years and also explained the reasons for delay in filing

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

9. The learned CIT(A) ought to have considered that several Judicial rulings and Circulars of the CBDT state that minor filing delays should not deny tax exemptions. 10. The Ld. CIT(A) ought to have appreciated that the assessee trust has satisfied conditions for claiming exemption for past many years and also explained the reasons for delay in filing

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

9. The learned CIT(A) ought to have considered that several Judicial rulings and Circulars of the CBDT state that minor filing delays should not deny tax exemptions. 10. The Ld. CIT(A) ought to have appreciated that the assessee trust has satisfied conditions for claiming exemption for past many years and also explained the reasons for delay in filing

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

13. In so far as appeal filed by the assessee for the A.Y 2020-21 is concerned, the learned CIT (A) in Para 6.2.8 has observed that in view of the order passed by the DGIT (Inv) u/s 119(2)(b) of the Act, dated 18/01/2024, the rectification order passed by the ACIT/CPC u/s 154 dated 27/09/2022 becomes infructuous

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 249(2) of the Act, hence the Delay cannot be condoned, and appeal cannot be admitted for adjudication hence rendered as inadmissible. 4. In the light of the above, the appellant had not given any substantive evidence for the late filing of appeal. The appellant assessee has not been able to demonstrate that sufficient cause existed for non-filing

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 is a cause that prevents an appellant from filing the appeal or application within the prescribed time limit and is beyond their control and not due to negligence or inaction. In the present case, going by the facts available on record, it is purely on account of inaction or negligence of the assessee

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 is a cause that prevents an appellant from filing the appeal or application within the prescribed time limit and is beyond their control and not due to negligence or inaction. In the present case, going by the facts available on record, it is purely on account of inaction or negligence of the assessee