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

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

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. 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 253(3) 5 ITA.No.1253/Hyd./2025 of the IT Act, 1961 and the delay in filing the appeal of 2345 days was beyond the control of the assessee. The learned Authorised Representative of the Assessee, accordingly, pleaded that the delay may please be condoned in the interest of substantial justice since the circumstances were beyond the control

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 253(3) 5 ITA.No.1253/Hyd./2025 of the IT Act, 1961 and the delay in filing the appeal of 2345 days was beyond the control of the assessee. The learned Authorised Representative of the Assessee, accordingly, pleaded that the delay may please be condoned in the interest of substantial justice since the circumstances were beyond the control

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

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

section 253(5) of the Income Tax Act, 1961 (“the Act”) is to be construed liberally, such liberal approach cannot be extended to cases where the delay is the result of inaction, negligence, or lack of bona fides on the part of the litigant. In the present case, the explanation furnished by the assessee does not inspire confidence. The demise

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

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

ELUMALAI SUMATHI,BAPATLA vs. INCOME TAX OFFICER, WARD-1, ONGOLE

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1165/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2016-17) Elumalai Sumathi Vs. Income Tax Officer Bapatla Ward-1 [Pan :Abipe4083C] Ongole (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By:: Shri U.Mini Chandran, Dr सुिवधई की तधरीख/Date Of Hearing: 18/12/2024 घोर्णध की तधरीख/Date Of 30/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 09.08.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre (Nfac), Delhi Pertaining To A.Y.2016-17 On The Following Grounds : 1. The Ld.Cit(A) Erred In Law & On Facts In Confirming The Addition Of Rs.36,60,000 As Unexplained Investment U/S 69 Of The Act After Having Admitted The Additional Evidence Filed By The Assessee Under Rule 46A. 2. Any Other Ground Or Grounds That May Be Urged At The Time Of Hearing.

delay. 4. We have gone through the condonation petition filed by the assessee. In this case, the order of the Ld.CIT(A) was passed and served on the assessee on 09.08.2024 and as per the amended provisions of section 253

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

SUJALA PIPES PRIVATE LIMITED,NANDYAL vs. ACIT, CIRCLE-1, KURNOOL

In the result, both the appeals of the assessee company are allowed for statistical purposes

Bench: Us:

condonation of delay involved in filing of the appeal. 14. The assessee company has filed before us an application seeking admission of certain documents as additional evidence, as under: a. Cash sales details for Rs. 1.39 Crs. b. Summary of cash deposits [Rs. 8.65 Crs] and withdrawals from various banks [Rs. 12.59] c. Bank statements related to 8 Banks

SUJALA PIPES PRIVATE LIMITED,NANDYAL vs. ACIT, CIRCLE-1, KURNOOL

In the result, both the appeals of the assessee company are allowed for statistical purposes

Bench: Us:

condonation of delay involved in filing of the appeal. 14. The assessee company has filed before us an application seeking admission of certain documents as additional evidence, as under: a. Cash sales details for Rs. 1.39 Crs. b. Summary of cash deposits [Rs. 8.65 Crs] and withdrawals from various banks [Rs. 12.59] c. Bank statements related to 8 Banks

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.

4 (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall in a case where any objection is received under sub-section (2), issue such directions, as it thinks fit, for the guidance of the Assessing Officer to enable him to complete the assessment