RR MARKETING,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

condone the delay involved in the filing of the present\nappeal.\nWe have heard the Learned Authorized Representatives of both\nparties, perused the orders of the lower authorities and the material\navailable on record, as well as considered the judicial pronouncements\nthat have been pressed into service by the Ld. AR to drive home his\ncontentions.\nShri A.V. Raghuram, Advocate

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

sections": [ "271D", "269SS", "11", "12AA", "143(1)", "154", "271E", "275(1)(c)", "273B" ], "issues": "Whether the delay in filing the audit report (Form 10B) was condonable

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

sections": [ "Sec. 143(1)", "Sec. 271D", "Sec. 154", "Sec. 250", "Sec. 10B", "Sec. 11", "Sec. 12", "Sec. 119(2)(b)", "Sec. 12AA", "Sec. 139(1)", "Sec. 119(2)(b)", "Sec. 132", "Sec. 153A", "Sec. 143(3)", "Sec. 269SS", "Sec. 271D", "Sec. 275(1)(c)", "Sec. 271E", "Sec. 119(2)(b)", "Sec. 273B", "Sec. 143(1

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

condonation and directed the Assessing Officer to reconsider the exemption claim. Regarding the penalty under Section 271D, the Tribunal found it unsustainable due to the absence of a recorded satisfaction by the Assessing Officer and the initiation of penalty proceedings after the period of limitation.", "result": "Allowed", "sections": [ "Sec. 143(1)", "Sec. 271D", "Sec. 154

KAKINADA INFRASTRUCTURE HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

delay of 506 days in filling the appeal is condoned.\n5.\nThe assessee has raised the following grounds of\nappeal:\n1. “The learned Commissioner of Income Tax (Appeals) erred in law\nand facts in upholding the disallowance of ₹15,30,650 incurred\ntowards advertisement expenditure, overlooking the business\nexpediency and commercial rationale behind the same.\n2. The learned lower authorities

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

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

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

NICHINO INDIA PRIVATE LIMITED (FORMERLY NICHINO CHEMICAL INDIA PRIVATE LIMITED NOW MERGED),HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.366/Hyd/2024 (धििाारण वर्ा / Assessment Year: 2020-21) Nichino India Private Dcit / Acit Limited (Formerly Nichino Vs. Circle-5(1) Chemical India Private Hyderabad Limited, Now Merged) Hyderabad [Pan : Aaecn5394B] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent धििााररती द्वारा/Assessee By: Ms.Suvibha Nolkha, Ar राजस्‍व द्वारा/Revenue By : Shri D.Praveen, Dr सुिवाई की तारीख/Date Of Hearing: 09/09/2024 घोर्णा की तारीख/Pronouncement On: 25/09/2024

section 154 of the Act and there was no subsequent opportunity to the assessee to make representation before the learned Assessing Officer and in such circumstances, assessee preferred the appeal against 143(1) order with a delay. 4. Learned CIT(A) refused to condone

MAHESWARI MINING & ENERGY PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri K. Narasimha Charyassessment Years: 2016-17 Maheswari Mining & Vs. Asst. Commissioner Of Energy Pvt. Ltd., Income-Tax, Hyderabad. Circle – 16(2), Hyderabad. Pan – Aagcm0805N (Appellant) (Respondent) Assessee By: S/Shri Y. Ratnamkar& B. Satyanarayana Murthy Revenue By: Shri Y.V.S.T. Sai Date Of Hearing: 21/04/2022 Date Of Pronouncement: /04/2022

condoned if there is sufficient compliance with the main requirements. This, however, did not in any manner tinker with the view that an ambiguous exemption clause should be interpreted favouring the revenue. Here again this Court applied different tests when considering the ambiguity of the exemption notification which requires strict construction and after doing so at the stage of applying

SURESH SAMAT HUF,SECUNDERABAD vs. DCIT, WARD-10(1), HYDERABAD

In the result, all the seven appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 154 of the Act, said application was required to be filed within a period of 4 years from the date of passing of the order. However, for the reasons best known to the assessee, the said application was not filed before the Assessing Officer within time. As the case may be the said application remained pending with

SURESH SAMAT HUF,SECUNDERABAD vs. DCIT, WARD-10(1), HYDERABAD

In the result, all the seven appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 154 of the Act, said application was required to be filed within a period of 4 years from the date of passing of the order. However, for the reasons best known to the assessee, the said application was not filed before the Assessing Officer within time. As the case may be the said application remained pending with

SURESH SAMAT HUF,SECUNDERABAD vs. DCIT, WARD-10(1), HYDERABAD

In the result, all the seven appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 154 of the Act, said application was required to be filed within a period of 4 years from the date of passing of the order. However, for the reasons best known to the assessee, the said application was not filed before the Assessing Officer within time. As the case may be the said application remained pending with

SURESH SAMAT HUF,SECUNDERABAD vs. DCIT, WARD-10(1), HYDERABAD

In the result, all the seven appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 154 of the Act, said application was required to be filed within a period of 4 years from the date of passing of the order. However, for the reasons best known to the assessee, the said application was not filed before the Assessing Officer within time. As the case may be the said application remained pending with

SURESH SAMAT HUF,SECUNDERABAD vs. DCIT, WARD-10(1), HYDERABAD

In the result, all the seven appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 154 of the Act, said application was required to be filed within a period of 4 years from the date of passing of the order. However, for the reasons best known to the assessee, the said application was not filed before the Assessing Officer within time. As the case may be the said application remained pending with