DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

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

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

condoning the delay. and the remaining ground nos.4 to 16 for discussion can be summarized as follows: 1) Ground 4: Disallowance of Rs.24,94,00,000 under section 40A(3) of the Act. 2) Grounds 5 to 7: Disallowance of Rs.21,08,45,001 under section 40(a)(ia) of the Act. 3) Grounds 8 and 9: Payments made

PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

271(1)(c) of the Act. Assuming for a moment, the assessee came to know the assessment order passed by the A.O only on 25/03/2022, but fact remains that still there is a delay of more than one year from the date she claimed to have received the assessment order or came to know about the assessment order passed

PARANJYOTHI THOTA,HYDERABAD vs. ACIT, CIRCLE-5(1), HYDERABAD

In the result, appeal filed by the assessee in ITA

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

271(1)(c) of the Act. Assuming for a moment, the assessee came to know the assessment order passed by the A.O only on 25/03/2022, but fact remains that still there is a delay of more than one year from the date she claimed to have received the assessment order or came to know about the assessment order passed

DINESH DAGA,HYDERABAD vs. ITO, WARD-5(1), HYDERABAD

In the result, appeal of the assessee is dismissed in limine

Bench: Shri Manjunatha G & Shri Ravish Sood

2 ITA.No.472/Hyd./2024 within the prescribed time limit before the Tribunal, which are as under : “AFFIDAVIT I, Dinesh Daga, son of Sri Prem Ratan Daga aged about 44 years, resident of H.No.4-8-831, Gowliguda, Hyderabad 500 012 do hereby solemnly affirm and state as under. I am the appellant herein and as such I know the facts

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

condonation of delay is rejected, and Page 5 of 12 ITA No.1164 & 2287/Hyd/2025 Srimad Virat Pottuluri Veera Brahmendra Swamula Vari Mattam consequently, the appeal filed by the assessee is dismissed as barred by limitation. 7. In the result, the appeal of the assessee in ITA No. 1164/Hyd/2025 is dismissed on account of limitation. ITA No.2287/Hyd/2025: 8. The brief facts

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)

section 271(1)(c) of the Act, dated 27/09/2022 for AY 2015-16. The assessee company has assailed the impugned order on the following grounds of appeal: “1. In the facts and circumstances of the case, the respected CIT(A) ought to have condoned the delay and decided the appeal on merits. 2

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)

section 271(1)(c) of the Act, dated 27/09/2022 for AY 2015-16. The assessee company has assailed the impugned order on the following grounds of appeal: “1. In the facts and circumstances of the case, the respected CIT(A) ought to have condoned the delay and decided the appeal on merits. 2

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)

section 271(1)(c) of the Act, dated 27/09/2022 for AY 2015-16. The assessee company has assailed the impugned order on the following grounds of appeal: “1. In the facts and circumstances of the case, the respected CIT(A) ought to have condoned the delay and decided the appeal on merits. 2

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)

section 271(1)(c) of the Act, dated 27/09/2022 for AY 2015-16. The assessee company has assailed the impugned order on the following grounds of appeal: “1. In the facts and circumstances of the case, the respected CIT(A) ought to have condoned the delay and decided the appeal on merits. 2

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)

section 271(1)(c) of the Act, dated 27/09/2022 for AY 2015-16. The assessee company has assailed the impugned order on the following grounds of appeal: “1. In the facts and circumstances of the case, the respected CIT(A) ought to have condoned the delay and decided the appeal on merits. 2

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)

section 271(1)(c) of the Act, dated 27/09/2022 for AY 2015-16. The assessee company has assailed the impugned order on the following grounds of appeal: “1. In the facts and circumstances of the case, the respected CIT(A) ought to have condoned the delay and decided the appeal on merits. 2

VENKATA SUJATHA CHRUVUPALLI,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(3), HYDERABAD

In the result, the appeal of the assessee is allowed

271/- being 3% of the turnover declared from the said business of Rs.13,19,42,368/- without relying on the audited books of accounts submitted by the appellant and hence the said addition is liable for deletion. Without of Prejudice to the Ground no.1 of appeal above; 2. That the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre

PRASANTH PUTTAMAREDDY,NELLORE vs. INCOME TAX OFFICER, WARD-1, NELLORE

In the result, the appeal filed by the assessee in ITA

Bench: the Ld. CIT(A).

condone the delay in filing of the appeal before the Ld. CIT(A) and restore the issue back to the file of the A.O. for reconsideration of the issue de novo in accordance with law. The A.O. is directed to consider the penalty under Section 271(1)(c) after completing the assessment proceedings as per law. 17. In the result

PRASANTH PUTTAMAREDDY,NELLORE vs. INCOME TAX OFFICER, WARD-1, NELLORE

In the result, the appeal filed by the assessee in ITA

Bench: the Ld. CIT(A).

condone the delay in filing of the appeal before the Ld. CIT(A) and restore the issue back to the file of the A.O. for reconsideration of the issue de novo in accordance with law. The A.O. is directed to consider the penalty under Section 271(1)(c) after completing the assessment proceedings as per law. 17. In the result

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

In the result, appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं / Ita No. 641/Hyd/2023 (निर्धारण वर्ा / Assessment Year: 2015-16) Suresh Productions, Dy. Commissioner Of Hyderabad Income Tax, Vs. [Pan No. Aajfs7306J] Central Circle-1(2), Hyderabad अपीलधर्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Shri A. Srinivas, Ar रधजस्‍व द्वधरध/Revenue By: Shri Waseem Ur Rehman, Dr सुिवधई की तधरीख/Date Of Hearing: 29/02/2024 घोर्णध की तधरीख/Pronouncement On: 29/02/2024 आदेश / Order Per K. Narasimha Chary, J.M: Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, (“Learned Cit(A)”), In The Case Of Suresh Productions (“The Assessee”) For The Assessment Year 2015-16, Assessee Preferred This Appeal With A Delay Of One Day. Learned Ar Explained That The Delay Is Due To Calculation Error. Heard Learned Dr. Delay Is Condoned.

Delay is condoned. 2. Only issue involved in this matter is whether the penalty under section 271(1)(c) of the Income

TOURS5 COM,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

Bench: Us:

Section 271(1)(b) of the Act. The assessee firm has assailed the impugned order on the following grounds of appeal before us: “1) The order of the learned CIT (A) is erroneous both on facts and in law; 2) The learned CIT (A) erred in holding that the notice u/s 148A(b) is validly issued when

TOURS5 COM,HYDERABAD vs. ITO., WARD-9(1), HYDERABAD

Bench: Us:

Section 271(1)(b) of the Act. The assessee firm has assailed the impugned order on the following grounds of appeal before us: “1) The order of the learned CIT (A) is erroneous both on facts and in law; 2) The learned CIT (A) erred in holding that the notice u/s 148A(b) is validly issued when

SHREEJI FOODS PRIVATE LIMITED,HYDERABAD vs. ITO., WARD-3(1), HYDERABAD

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

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2014-15 M/S. Shreeji Foods Private Vs. The Income Tax Officer, Ward – 3(1), Limited, Hyderabad. Hyderabad. Pan : Aalcs2695H (Appellant) (Respondent) Assessee By: Shri Sunil Kumar Jain, C.A. Revenue By: Dr. Sachin Kumar, Sr.D.R. Date Of Hearing: 09.01.2025 15.01.2025 Date Of Pronouncement:

2. The learned CIT (A) has erred in upholding the wrongly passed order by assessing officer under section 147 read with section 144B of the Income Tax Act 1961, which is against the principles of natural justice as the assessing officer has not given the opportunity to the assesse to represent himself. 3. The learned CIT (A) has erred upholding

SAMPATH REDDY VEM,WARANGAL. vs. ITO., WARD-1, WARANGAL.

In the result, the appeal in ITA No

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1229 & 1230/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) Shri Sampath Reddy Vem Vs. Income Tax Officer Warangal Ward-1 Pan:Adfpv3598L Warangal (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: Theses Appeals Are Filed By Shri Sampath Reddy Vem (“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 23.05.2025 & 24.05.2025 Respectively For The A.Y 2014-15. As Both The Appeals Are Related To The Same Assessee Therefore, For The Purpose Of Convenience & Brevity, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

2. a) The Learned CIT(A), NFAC, erred in law and on facts in dismissing the appeal in limine without properly appreciating the reasons for the .delay in filing the appeal. b) The Learned CIT(A), NFAC failed to consider that the delay in filing the appeal was neither deliberate nor willful, but occurred due to bona fide circumstances beyond

SAMPATH REDDY VEM,WARANGAL. vs. ITO., WARD - 1, WARANGAL.

In the result, the appeal in ITA No

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1229 & 1230/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) Shri Sampath Reddy Vem Vs. Income Tax Officer Warangal Ward-1 Pan:Adfpv3598L Warangal (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: Theses Appeals Are Filed By Shri Sampath Reddy Vem (“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 23.05.2025 & 24.05.2025 Respectively For The A.Y 2014-15. As Both The Appeals Are Related To The Same Assessee Therefore, For The Purpose Of Convenience & Brevity, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

2. a) The Learned CIT(A), NFAC, erred in law and on facts in dismissing the appeal in limine without properly appreciating the reasons for the .delay in filing the appeal. b) The Learned CIT(A), NFAC failed to consider that the delay in filing the appeal was neither deliberate nor willful, but occurred due to bona fide circumstances beyond