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

delay. Once the condonation is rejected, the appeal become non-est and the Ld.CIT(A) should not have proceeded to take up the appeal on merits. Even on merits, the following is submitted for kind consideration of the Hon'ble Bench. In respect of status of assessment of companies/shareholders who contributed the share capital of Rs, 311 crores

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

2. At the outset, there is a delay of 2345 days in filing the above appeals before 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 and misguidance with the appointed learned counsel regarding

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

2. At the outset, there is a delay of 2345 days in filing the above appeals before 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 and misguidance with the appointed learned counsel regarding

D PEDA REDDAIAH ,KADAPA vs. INCOME TAX OFFICER, WARD-1, PRODDUTUR

In the result, assessee’s appeal is treated as allowed for statistical purposes

Bench: Smt. P. Madhavi Deviassessment Year: 2010-11 Shri D. Pedda Reddaiah Vs. Income Tax Officer Prop:Sri Lakshmi Ward-1 Proddatur Venkateswara Wines, Kadapa Distt. Pan:Agipd1836F (Appellant) (Respondent) Assessee By: Sri K.C. Devdas Revenue By: Smt. M. Narmada, Dr Date Of Hearing: 12/03/2020 Date Of Pronouncement: 30/04/2020 Order This Is Assessee’S Appeal For The A.Y 2010-11 Filed Against The Order Of The Cit (A)-Kurnool, Dated 4.3.2015. 2. At The Outset It Is Seen That There Is A Delay Of 1422 Days In Filing Of This Appeal Before The Tribunal. The Assessee Has Filed An Application For Condonation Of Delay Stating As Under: “1. I, D. Peda Reddaiah, S/O D.Subbarayudu, Aged About 47 Years, Prop. Of Sri Lakshmi Venkateswara Wines, Housed At 11/231, Badvel Road, Mydukur Village, Kadapa District, Andhra Pradesh, Do Solemnly Affirm & State As Under: 2. I Am An Illiterate & Not Well Conversant With The Statutory Provisions & I Carried On Business In Wines For Two Years At Mydkur Village. I Don'T Have Any Formal Education. 3. I Have Carried On Wines Business Under The Name & Style Of Sri Lakshmi Venkateswara Wines For About Two Page 1 Of 11

Section 253(1)(c) of the Act. 6.2. The reason, we have come to the conclusion that the counsel for the Assessee would have taken instructions from the Assessee in preparing the petition for condonation of delay, is, because, the name of the Chartered Accountant is mentioned in the petition. Learned counsel could not have conjured up the name

REVANTH REDDY ANUMALA,BANJARA HILLS vs. A.C.I.T CENTRAL CIRCLE-1(2), HYDERABAD

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed in the section has also been used identically in sub- section 3 of section

JASPER AUTO SERVICES PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

In the result, appeal of the assessee is partly allowed for statistical purposes, in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2014-15 Jasper Auto Services Pvt. Vs. Dy. Commissioner Of Ltd., Hyderabad. Income-Tax, Circle – 2(1), Hyderabad. Pan – Aaccb 0196P (Appellant) (Respondent)

section 2(42C) of the Act. 3 (a) The Ld. CIT(A) erred in confirming the disallowance 0 expenditure to the extent of Rs.12,14,253/- (b) The ld. CIT (A) ought to have appreciated that the agreement of the assessee's AR for the disallowance of Rs. 12,14,253/-, during the course of assessment proceedings, has not been

SRIMAD VIRAT POTTULURI VEERA BRAHMENDRA SWAMULA VARI MATTAM,CUDDAPAH vs. ITO., EXEMPTION WARD, TIRUPATHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1164/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer Brahmendra Swamula Vari Exemption Ward, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Appellant) (Respondent) आ.अपी.सं /Ita No.2287/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer, Brahmendra Swamula Vari Exemption Ward, Chittoor, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Ravindra Chenji, Advocate (Through Hybrid Mode) राज" व "वारा/Revenue By:: Ms. Payal Gupta, Sr.Ar सुनवाई क" तार"ख/Date Of Hearing: 09/02/2026 घोषणा क" तार"ख/Pronouncement: 13/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: The Captioned Appeals Are Filed By Srimad Virat Pottuluri Veera Brahmendra Swamula Vari Mattam (“The Assessee”), Feeling Aggrieved By The

2 of 12 ITA No.1164 & 2287/Hyd/2025 Srimad Virat Pottuluri Veera Brahmendra Swamula Vari Mattam Endowment Authority for appointment of a new Mattam of the Trust. Accordingly, the Ld. AR submitted that there was reasonable cause for the delay in filing of the appeal before the Tribunal and therefore, prayed for the condonation of the delay and admission of the appeal

SRIMAD VIRAT POTHULURI VEERABRAHMENDRA SWAMULAVARI MUTTAM,KADAPA vs. ITO, EXEMPTION WARD, TIRUPATI, TIRUPATI

In the result, the appeal of the assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1164/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer Brahmendra Swamula Vari Exemption Ward, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Respondent) (Appellant) आ.अपी.सं /Ita No.2287/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer, Brahmendra Swamula Vari Exemption Ward, Chittoor, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Respondent) (Appellant) निर्धारिती द्वारा/Assessee By: Shri Ravindra Chenji, Advocate (Through Hybrid Mode) राजस्व द्वारा /Revenue By:: Ms. Payal Gupta, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 09/02/2026 घोषणा की तारीख/Pronouncement: | 13/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: The Captioned Appeals Are Filed By Srimad Virat Pottuluri Veera Brahmendra Swamula Vari Mattam (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 21/08/2023 & 21/10/2025 Respectively For The A.Y.2016-17.

2. At the outset, it is noticed that there is a delay of 632 days in filing the present appeal before this Tribunal. In this regard, the assessee has filed a petition seeking condonation of delay along with an affidavit explaining the reasons for such delay. The explanation put forth by the assessee is that the founder ("Mattam

GAYATRI PROJECTS LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, these three appeals of the Assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1111, 1112 & 1113/Hyd/2025 Assessment Years 2018-2019, 2020-2021 & 2021-2022 Gayatri Projects Limited, The Dcit, Hyderabad – 500 082. Vs. Circle-2(1), Telangana. Hyderabad – 500 084. Pan Aaacg8040K (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri S Rama Rao, Advocate राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

253(3) of the Income Tax Act, 1961. 2. Corporate Insolvency Resolution Process (CIRP") was commenced by Hon'ble National Company Law Tribunal (NCLT), 3 ITA.Nos.1111, 1112 and 1113/Hyd./2025 Hyderabad Bench vide order dated 15th November 2022 in the case of appellant company and Resolution Professional (RP) was appointed who is required to manage the operations of company

GAYATRI PROJECTS LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, these three appeals of the Assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1111, 1112 & 1113/Hyd/2025 Assessment Years 2018-2019, 2020-2021 & 2021-2022 Gayatri Projects Limited, The Dcit, Hyderabad – 500 082. Vs. Circle-2(1), Telangana. Hyderabad – 500 084. Pan Aaacg8040K (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri S Rama Rao, Advocate राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

253(3) of the Income Tax Act, 1961. 2. Corporate Insolvency Resolution Process (CIRP") was commenced by Hon'ble National Company Law Tribunal (NCLT), 3 ITA.Nos.1111, 1112 and 1113/Hyd./2025 Hyderabad Bench vide order dated 15th November 2022 in the case of appellant company and Resolution Professional (RP) was appointed who is required to manage the operations of company

GAYATRI PROJECTS LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, these three appeals of the Assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1111, 1112 & 1113/Hyd/2025 Assessment Years 2018-2019, 2020-2021 & 2021-2022 Gayatri Projects Limited, The Dcit, Hyderabad – 500 082. Vs. Circle-2(1), Telangana. Hyderabad – 500 084. Pan Aaacg8040K (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri S Rama Rao, Advocate राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

253(3) of the Income Tax Act, 1961. 2. Corporate Insolvency Resolution Process (CIRP") was commenced by Hon'ble National Company Law Tribunal (NCLT), 3 ITA.Nos.1111, 1112 and 1113/Hyd./2025 Hyderabad Bench vide order dated 15th November 2022 in the case of appellant company and Resolution Professional (RP) was appointed who is required to manage the operations of company

VAGDEVI REDDY TANDUR,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

253 ITR 798held as under: "In exercising discretion under section 5 of the Limitation Act the Courts should adopt a pragmatic approach. A distinction must be made between a case where the delay is inordinate and a case where the delay is of a few days. Whereas in the former case the consideration of prejudice to the other side will

DY.CIT, CIRCLE-1(2),, HYDERABAD vs. M/S CONCORD DRUGS LTD.,, HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

condone the delay in filing the appeal before us on the ground that the assessee was prevented by reasonable cause in filing the appeal belatedly. Accordingly, we admit the appeals for hearing and adjudication. 4. As the facts and grounds raised are similar in all the three appeals of the assessee and three appeals of the revenue, except the quantum

DY.CIT, CIRCLE-1(2),, HYDERABAD vs. M/S CONCORD DRUGS LTD.,, HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

condone the delay in filing the appeal before us on the ground that the assessee was prevented by reasonable cause in filing the appeal belatedly. Accordingly, we admit the appeals for hearing and adjudication. 4. As the facts and grounds raised are similar in all the three appeals of the assessee and three appeals of the revenue, except the quantum

CONCORD DRUGS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

condone the delay in filing the appeal before us on the ground that the assessee was prevented by reasonable cause in filing the appeal belatedly. Accordingly, we admit the appeals for hearing and adjudication. 4. As the facts and grounds raised are similar in all the three appeals of the assessee and three appeals of the revenue, except the quantum

DY.CIT, CIRCLE-1(2),, HYDERABAD vs. M/S CONCORD DRUGS LTD.,, HYDERABAD

In the result appeals of the assessee in all the years under consideration are allowed and the appeals of the revenue are dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

condone the delay in filing the appeal before us on the ground that the assessee was prevented by reasonable cause in filing the appeal belatedly. Accordingly, we admit the appeals for hearing and adjudication. 4. As the facts and grounds raised are similar in all the three appeals of the assessee and three appeals of the revenue, except the quantum

SKYBRIDGE SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, (TP)-2 HYDERBAD, HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar(Through Virtual Mode) & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2021-22 Skybridge Solutions Vs. The Deputy Commissioner Of Private Limited, Income Tax, Hyderabad, (Transfer Pricing)-2, H.No.8-2-239/L/83-A, Hyderabad. Plot No.83/A, Mla Colony, Road No.12, Banjara Hills, Hyderabad – 500034, Telangana. Pan : Aalcs1899M. (Appellant) (Respondent) Assessee By: Shri Mahesh Raichandani, C.A. Revenue By: Ms. K. Haritha, Cit-Dr Date Of Hearing: 23.04.2024 Date Of Pronouncement: 29.04.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2021-22 Arises From The Impugned Assessment Order Passed U/S 143(3) R.W.S. 144C(3) R.W.S. 144B Of The Income Tax Act Dated 26.12.2023. 2. The Brief Facts Of The Case Are That The Assessee Is A Software Development & Services Company, Filed Its Income Tax Return For The Assessment Year 2021-22 On 09.03.2022, Declaring A Total Income Of Rs.1,06,49,030. The Return Was Processed Under Section 143(1)(A) Of The Income Tax Act On 24.08.2022. Subsequently, The Case Was Selected For Scrutiny Under Cass & A Notice Under Section 143(2) Was Issued On 28.06.2022, To Which The Assessee Responded On 15.07.2023. Thereafter, A Reference Under Section 92Ca(1) Was Made To The Transfer Pricing Officer (Tpo) To Determine The Arm'S Length Price For Transactions With Associated Enterprises. The Tpo, Through An Order Dated 31.10.2023, Directed An Upward Adjustment Of Rs.1,83,25,993 To The Assessee'S Income For The Financial Year 2020-21. Consequently, A Show Cause Notice Was Issued To The Assessee On November 9, 2023, Regarding The Proposed Adjustment, Along With A Penalty Initiation Under Section 270A.

2), 144C(3) and 144C(5) of the Act clearly shows that, in case, the assessee fails to raise any objection against the draft assessment order, then the AO was left with no other option, but to pass the assessment order as required u/s. 144C(3) of the Act. The order to be passed by the AO u/s. 144C

SRISAILA KSHETRA YOGI VEMA REDDY NITHYANNADANA SATRAM,KURNOOL vs. ITO, EXEMPTION WARD, TIRUPATI

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

Bench: Shri Laliet Kumarassessment Year: 2017-18 Srisaila Kshetra Yogi Vema Vs. The Income Tax Officer, Exemption Ward, Reddy Nityannadana Satram, Tirupati. Kurnool, Andhra Pradesh. Pan : Aadts7734G. (Appellant) (Respondent) Assessee By: Shri Gbs Maitreya Revenue By: Ms. Reema Yadav. Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023

253 ITR 798held as under:"In exercising discretion under section 5 of the Limitation Act the Courts should adopt a pragmatic approach. A distinction must be made between a case where the delay is inordinate and a case where the delay is of a few days. Whereas in the former case the consideration of prejudice to the other side will