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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

275(1)(c) and therefore, is deserved to be quashed. 5. The Ld. CIT(A) failed to consider that the initiation and levy of penalty u/s 271D of the Act is not sustainable as the AO has not recorded his satisfaction for initiation of penalty proceedings u/s 271D of the Act in contravention to the provisions of section 269SS

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

275(1)(c) and therefore, is deserved to be quashed. 5. The Ld. CIT(A) failed to consider that the initiation and levy of penalty u/s 271D of the Act is not sustainable as the AO has not recorded his satisfaction for initiation of penalty proceedings u/s 271D of the Act in contravention to the provisions of section 269SS

SRI SOMESHWARA LAXMI NARASIMHA SWAMY TEMPLE PALAKURTHY,WARANGAL vs. CIT (EXEMPTIONS), HYDERABAD

In the result, all the four appeals of the assessee are allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

condone the delay of 13 days, 11 days and 14 days in filing these appeals before the Ld.CIT(A) for the A.Y. 2015-16, 2016-17 and 2018-19 respectively. 7. On the merits of the issue, the Ld.AR of the assessee has submitted that the AO has assessed the entire hundi collection/donations, without allowing the corresponding expenditure incurred

SRI SOMESHWARA LAXMI NARASIMHA SWAMY TEMPLE PALAKURTHY,WARANGAL vs. ITO., EXEMPTION, WARD-1(4), HYDERABAD

In the result, all the four appeals of the assessee are allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

condone the delay of 13 days, 11 days and 14 days in filing these appeals before the Ld.CIT(A) for the A.Y. 2015-16, 2016-17 and 2018-19 respectively. 7. On the merits of the issue, the Ld.AR of the assessee has submitted that the AO has assessed the entire hundi collection/donations, without allowing the corresponding expenditure incurred

SRI SOMESHWARA LAXMI NARASIMHA SWAMY TEMPLE PALAKURTHY,WARANGAL vs. ITO., EXEMPTION, WARD-1(4), HYDERABAD

In the result, all the four appeals of the assessee are allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

condone the delay of 13 days, 11 days and 14 days in filing these appeals before the Ld.CIT(A) for the A.Y. 2015-16, 2016-17 and 2018-19 respectively. 7. On the merits of the issue, the Ld.AR of the assessee has submitted that the AO has assessed the entire hundi collection/donations, without allowing the corresponding expenditure incurred

SRI SOMESHWARA LAXMI NARASIMHA SWAMY TEMPLE PALAKURTHY,WARANGAL vs. ITO., EXEMPTION WARD-1(4), HYDERABAD

In the result, all the four appeals of the assessee are allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

condone the delay of 13 days, 11 days and 14 days in filing these appeals before the Ld.CIT(A) for the A.Y. 2015-16, 2016-17 and 2018-19 respectively. 7. On the merits of the issue, the Ld.AR of the assessee has submitted that the AO has assessed the entire hundi collection/donations, without allowing the corresponding expenditure incurred

SRI SOMESHWARA LAXMI NARASIMHA SWAMY TEMPLE PALAKURTHY,WARANGAL vs. ITO., WARD-3, WARANGAL.

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.326/Hyd/2025 Assessment Year 2017-2018 Sri Someshwara Laxmi Narasimha Swamy Temple, The Income Tax Officer, Vs. Ward-3, Palakurthy, Warangal – 506001 Warangal – 506 252. Telangana. Pan Aagas8382Q (Appellant) (Respondent) निर्धारिती द्वधिध/Assessee By : Ca Ka Sai Prasad िधजस् व द्वधिध/Revenue By : Dr. Sachin Kumar, Sr. Ar सुिवधई की तधिीख/Date Of Hearing: 29.01.2026 घोषणध की तधिीख/Pronouncement: 06.02.2026 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 27.02.2024 Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac], Delhi, For The Assessment Year 2017-2018. 2

275 days in filing the appeal subject to cost of Rs.1000/- to be deposited in the Prime Minister’s National Relief Fund. Hence, in the facts and circumstances of the case and in view of the earlier decision of this Tribunal, we take a lenient to condone the delay of 301 days in filing the present appeal subject to cost

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these appeals is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 3. As the grounds are common in all these appeals, but the financial results are different in all the above assessment years . For the sake and brevity

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these appeals is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 3. As the grounds are common in all these appeals, but the financial results are different in all the above assessment years . For the sake and brevity

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)., HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED., HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these appeals is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 3. As the grounds are common in all these appeals, but the financial results are different in all the above assessment years . For the sake and brevity

DCIT, CIRCLE-2(1), HYDERABAD, HYDERABAD vs. KSK ENERGY COMPANY PRIVATE LIMITED, HYDERABAD, HYDERABAD

In the result, all the appeals of revenue are allowed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

delay in filing these appeals is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Cases are now taken up for adjudication on merits. 3. As the grounds are common in all these appeals, but the financial results are different in all the above assessment years . For the sake and brevity

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE 3(4), HYDERABAD

275/- (Rs.13,600/- as per order under section 154, dated 19/04/2022), the CIT(A) observed that as the assessee company had not submitted any details for substantiating its claim that there was no short deduction or short payment/collection of tax, therefore, the said claim being devoid and bereft of any substance was liable to be rejected. 10. Apropos the challenge

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(4), HYDERABAD

Accordingly, the appeal filed by the assessee company, being devoid and bereft of any substance, is dismissed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1236 & 1237/Hyd/2025 ("नधा"रण वष"/Assessment Year:2021-22 & 2022-23) Vivimed Labs Limited, Vs. Dcit, Hyderabad. Central Circle-3(4), Pan: Aaacv6060A Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई क" तार"ख/Date Of 05/01/2026 Hearing: घोषणा क" तार"ख/Date Of 21/01/2026 Pronouncement: आदेश / Order

275/- (Rs.13,600/- as per order under section 154, dated 19/04/2022), the CIT(A) observed that as the assessee company had not submitted any details for substantiating its claim that there was no short deduction or short payment/collection of tax, therefore, the said claim being devoid and bereft of any substance was liable to be rejected. 10. Apropos the challenge

RAAJASEKAR JEEVITHA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

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

Bench: Shri Laliet Kumarassessment Year: 2017-18 Rajasekar Jeevitha, Vs. The Asst.Commissioner Of C/O.P. Murali & Co., Income Tax, Chartered Accountants, Central Circle – 2(3), 6-3-655/2/3, Hyderabad. Somajiguda, Hyderabad - 500082 Pan : Aagpj7813A (Appellant) (Respondent) Assessee By: P. Murali Mohan Rao, C.A. Revenue By: Shri A.P. Babu, Sr. Ar Date Of Hearing: 05.10.2023 Date Of Pronouncement: 05.10.2023

c) of Section 138 of the Negotiable Instruments Act, 1881 and any other laws, which prescribe period(s) of limitation for instituting proceedings, outer limits (within which the court or tribunal can condone delay) and termination of proceedings.” Applying the said decision in the present case, the time limit for passing penalty order u/s 272A

M/S SUJANA TOWERS LIMITED,HYDERABAD vs. ACIT, CIRCLE 3(1), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2008-09

condone the delay as the assessee was prevented by reasonable cause in not filing the appeal within the stipulated time. 2 I.T.A. No. 79/Hyd/2014 M/s Sujana Towers Ltd. 3. Briefly the facts of the case are, the assessee is a Company engaged in the manufacture of Iron and steel products, Telecom Products and Power Transmission Towers. It filed its return

DCIT., CENTRAL CIRCLE 3(1),, HYDERABAD vs. UNITED DEVELOPER, HYDERABAD

In the result, the cross-objections file d by the assessee firm in A

Bench: Us As A Cross-Objector. Since Common Issues Are Involved In The Captioned Appeals & Cross-Objections, Therefore, The Same Have Been Taken Up & Disposed Of By A Consolidated Order. We Shall First Take Up The Appeal Filed By The Revenue & The Cross- Objection Of The Assessee Firm For A.Y.2016-17 & The Order Therein Passed Shall Apply Mutatis Mutandis For The Purpose Of Disposing Of The Other Appeal & Cross-Objection.

condonation of the delay involved in filing the appeal. 20. As the assessee firm vide its cross objection has assailed the validity of the addition of Rs. 9.45 crores (supra) made by the AO on account of the alleged unaccounted sale consideration received by the assessee firm in cash, therefore, we deem it apposite to first deal with the said

DCIT., CENTRAL CIRCLE-3(1), HYDERABAD vs. UNITED DEVELOPER, HYDERABAD

In the result, the cross-objections file d by the assessee firm in A

Bench: Us As A Cross-Objector. Since Common Issues Are Involved In The Captioned Appeals & Cross-Objections, Therefore, The Same Have Been Taken Up & Disposed Of By A Consolidated Order. We Shall First Take Up The Appeal Filed By The Revenue & The Cross- Objection Of The Assessee Firm For A.Y.2016-17 & The Order Therein Passed Shall Apply Mutatis Mutandis For The Purpose Of Disposing Of The Other Appeal & Cross-Objection.

condonation of the delay involved in filing the appeal. 20. As the assessee firm vide its cross objection has assailed the validity of the addition of Rs. 9.45 crores (supra) made by the AO on account of the alleged unaccounted sale consideration received by the assessee firm in cash, therefore, we deem it apposite to first deal with the said

NEERAJ KUMAR AGARWAL ,HYDERABAD vs. INCOME TAX OFFICER, HYDERABAD

In the result, the appeal of the assessee is allowed

section 154 of the Income Tax Act, 1961. (e) The Ld. CIT(A) ought to have followed the ratio laid down by the Apex Court in the case of ITO v. Volkart Brothers and Others, 82 ITR 50 (S.C.) with regard to mistake apparent from record that qualities for an action