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

In the result, three appeals i

253 or an appeal to the High Court under section 260A\nor an appeal to the Supreme Court under section 261 or revision\nunder section 263 or section 264 and an order imposing or enhancing\nor reducing or cancelling penalty or dropping the proceedings for the\nimposition of penalty is passed before the order of the Commissioner\n(Appeals

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

253 or an appeal to the High Court under section 260A\nor an appeal to the Supreme Court under section 261 or revision\nunder section 263 or section 264 and an order imposing or enhancing\nor reducing or cancelling penalty or dropping the proceedings for the\nimposition of penalty is passed before the order of the Commissioner\n(Appeals

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

253(5) of the Act, the Tribunal\nmay admit an appeal filed beyond the period of limitation where it\nis satisfied that there was sufficient cause for not presenting the\nappeal within the prescribed time. The explanation of the assessee\ntherefore becomes relevant to determine whether the same reflects\nsufficient cause on his part in not presenting the present appeals

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

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

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

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

253 or an appeal to the High Court under section 260A\nor an appeal to the Supreme Court under section 261 or revision\nunder section 263 or section 264 and an order imposing or enhancing\nor reducing or cancelling penalty or dropping the proceedings for the\nimposition of penalty is passed before the order of the Commissioner\n(Appeals

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

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

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

253 of the Act", "Section 249 of the Income Tax Act", "Section 5 of the Limitation Act", "Section 119 of the Income Tax Act, 1961" ], "issues": "1. Whether the delay in filing the appeal can be condoned due to a sufficient cause. 2

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

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

condonation of delay is rejected, and\nconsequently, the appeal filed by the assessee is dismissed as barred by\nlimitation.\n7. In the result, the appeal of the assessee in ITA No. 1164/Hyd/2025 is\ndismissed on account of limitation.\nITA No.2287/Hyd/2025:\n8. The brief facts of the case in the present appeal are that the assessee is\na religious trust, which

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

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

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