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

9 as under:\n“5. In Commr. of Income Tax, U.P. v. Kanpur Coal Syndicate\nMANU/SC/0123/1964: [1964]531TR225(SC) a three Judge Bench\nof this Court discussed the scope of Section 31(3)(a) of the Income\nTax Act, 1922 which is almost identical to Section 251(1)(a). The\nCourt held as under

SURESH PRODUCTIONS ,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeal of assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

Delay is condoned. 2. Penalty in this matter is levied under section 270A(9) of the Act on the ground

KARIMNAGAR MILK PRODUCER COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE-1, KARIMNAGAR

270A of the Act before the CIT(A). As the appeal filed\nby the assessee company involved a delay of 36 days, therefore, the\nassessee company had filed before him an application seeking\ncondonation of the same. However, the CIT(A) did not find favor with\nthe explanation of the assessee company regarding the reasons\n\nleading to the delay

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERBAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

270A of the Act for AY 2017-18 and AY 2018-19. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of vide a consolidated order. 2. We shall first take up the appeal filed by the assessee company in ITA No.1501/Hyd/2025 for AY 2016-17, which arises from

NIRAJITA MITRA,HYDERABAD vs. ITO., WARD-12(4), HYDERABAD

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

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

270A as under reporting of income. Accordingly, ground nos.1 to 6 are dismissed.” 7. It was the contention of the ld. AR that the ld.CIT(A) has not condoned the delay of 4 days and dismissed the application for grant of immunity and confirmed the penalty. It was further submitted by the ld. AR that the matter may kindly

ORBIS REAL ESTATE FUND I,HYDERABAD (AUTH. REP.) vs. ADIT (INTERNATIONAL TAXATION)-2 - 2, HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

delay of 356 days in filing the appeal is condoned, and the appeal is admitted for adjudication on merits. 3. The grounds of appeal of the assessee are as under : “ (1) The Ld. AO erred in not considering the residential status of the Appellant and he/she has erred in disputing the TRC issued by the government authorities of Mauritius

MADHAVI BEERAVOLU,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(1), HYDERABAD

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

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

9. Aggrieved, the assessee has assailed before us the respective orders passed by the CIT(A) upholding the penalty imposed by the AO vide his orders, viz., (i) under section 271AAC(1) of the Act, dated 08/08/2022; and (ii) under section 270A of the Act, dated 05/09/2024. 10. Sri Veeravenkata Satya Shiva Ryali, the Learned Authorized Representative (for short

MADHAVI BEERAVOLU,HYDERABAD vs. INCOME TAX OFFICER, WARD-8(1), HYDERABAD

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

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

9. Aggrieved, the assessee has assailed before us the respective orders passed by the CIT(A) upholding the penalty imposed by the AO vide his orders, viz., (i) under section 271AAC(1) of the Act, dated 08/08/2022; and (ii) under section 270A of the Act, dated 05/09/2024. 10. Sri Veeravenkata Satya Shiva Ryali, the Learned Authorized Representative (for short

PRAMEELA PORIKA,SURYAPET vs. ACIT., CIRCLE-7(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.593/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Smt. Prameela Porika Vs. Acit Suryapet Circle 7(1) Pan:Almpp8561C Suryapet (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S. Sandhya राज" व "ारा/Revenue By:: Shri Rakesh Chintagumpula, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 11/11/2025 घोषणा की तारीख/Pronouncement: 11/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Prameela Porika (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, (Nfac), Delhi (“Ld. Cit(A)”) Dated 27.10.2023 For The A.Y 2017-18. Page 1 Of 7

270A of the Act, and the medical evidence placed on record shows that the Page 3 of 7 ITA No 593 of 2025 Prameela Porika assessee was under medical treatment around the relevant period. The sequence of events explained by the assessee is consistent, reasonable, and supported by documents. We find no mala fide intention on the part

PRAJYOTH KUMAR ADI,HYDERABAD vs. ITO, WARD-4(1), HYDERABAD

In the result, both the appeals filed by the assessee are allowed for statistical purposes in terms of our aforesaid observations

Bench: us: “1. On the facts and in the circumstances of the case, the order of the Id. CIT(A) is erroneous both on facts and in law, and is passed in gross violations of principles of natural justice.

270A of the Act for under reporting of income Prajyoth Kumar Adi vs. ITO in consequence of misreporting of income regarding the aforesaid addition. 6. Accordingly, the AO based on the aforesaid facts vide his order passed under section 147 r.w.s 144 r.w.s 144B of the Act, dated 17/12/2024 determined the income of the assessee at Rs.1

MAHESHWAR REDDY KURA,HYDERABAD vs. INCOME TAX OFFICER, WARD-2, KARIMNAGAR

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

Bench: the Ld. CIT(A).

270A for misreporting and underreporting, under Section 271AAC(1) for unexplained investment, and under Section 272A(1)(d) for non-compliance with notices, and 3 Maheshwar Reddy Kura issued the final demand after charging interest under Sections 234A, 234B and 234C of the Act. 3. Aggrieved with the assessment order, the assessee preferred appeal before

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.

270A for under-reporting income and section 272A(1)(d) for non-compliance with notices were initiated separately. 3. The Registry has objected that the present appeal is not maintainable as per section 253(1)(d) of the Act. In the present case, AO has passed draft assessment order on 22/11/2023. Against that draft assessment order, assessee has not filed

MBR EDUCATIONAL SOCIETY,HYDERABAD vs. ITO., EXEMPTION WARD-1(2), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.665/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Mbr Educational Society Vs. Income Tax Officer Hyderabad Exemption Ward 1(2) Pan:Aaaam6527D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri B. Satyanarayana Murthy, Ca राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 04/12/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

delay of 441 days in filing the present appeal before this Tribunal. Page 1 of 9 ITA No 665 of 2025 MBR Educational Society The assessee has filed a condonation petition along with an affidavit explaining the reasons which, according to the assessee, constituted sufficient cause for the belated filing of the appeal. The copy of the affidavit filed

INCOME TAX OFFICER, WARD-1, NELLORE vs. VENKATA RAMANAMMA SAKAMURI, NELLORE

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

Bench: Us:

270A. The appellant challenged the procedural lapses, including non- compliance with Sections 148A(b), 149, and 151, and seeks relief on these grounds. Reliance is placed on relevant case law, including the decision in Kankanala Ravindra Reddy v. ITO, favoring procedural adherence. The appellant requests a condonation of delay in filing the appeal, citing health and mental distress