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

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. DCIT., CIRCLE-13(1), HYDERABAD

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.283, 284 & 286/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं / Ita Nos.300, 301 & 308/Hyd/2024 (निर्धारण वर्ष/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Dy. Cit, Circle 13(1) Hyderabad Singareni Collieries Company Limited Kothagudem Pan:Aaact8873F (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V.Anil Kumar, Advocate राजस्व द्वारा / Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 10/06/2025 घोषणा की तारीख / Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

disallowed by the Assessing Officer by holding that the generation of electricity is not production of any article or thing as per Section 32AC of the I.T. Act, 1961 and therefore, in the absernce of inclusion of the power generation in the purview of section 32AC of the Act, the benefit of the said provisions has been excluded

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

271(1)(c) of the Act. That penalty being impossible for concealment of income consequent to scrutiny assessment ITA No.912/Hyd/2024 23 order under Section 143(3) of the Act, it has no application to the present facts involving demand of additional tax on simple processing of income. As noted above, processing of a return under Section

SRINI PHARMACEUTICALS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

section 274 read with sec,271(1)(c) of the Act. Further, the Assessing Officer had also levied penalty u/sec.271(1)(c) of the Act for furnishing inaccurate particulars of income. Therefore, there is no merit in the ground taken by the assessee company and thus, rejected. 8 ITA.No.1121/Hyd./2025 9. In so far as levy of penalty u/sec.271

GADDAM MOHAN REDDY,NIZAMABAD vs. INCOME TAX OFFICER, WARD 1, NIZAMABAD, NIZAMABAD

Bench: the AO during re-assessment proceedings.4. The authorities below further failed to appreciate that on the same set of facts, the AO with all his expertise on the provisions of the Act has allowed the deduction claimed Under Section 54F of the Act in the assessment order passed Under Section 143(3) r.w.s Section 147 of the Act and that deduction claimed by the appellant Under Section 54F of the Act was by inadvertent.

disallowed the assessee’s claim for deduction under section 54F insofar the same pertained to the short-term capital gains of 5 Gaddam Mohan Reddy vs. ITO Rs.16,29,727/-. The AO while culminating the assessment, inter alia, initiated penalty proceedings under section 274 r.w.s 271

SOFT POINT TECHNOLOGIES PRIVATE LIMITED (FORMERLY KNOWN AS COLOR CHIPS ANIMATION PARK LIMITED),HYDERABAD vs. INCOME TAX OFFICER, WARD-3(4) , HYDERABAD

In the result, appeal of the assessee is allowed

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

section 271(1) of the Act, the amount added or disallowed in computing the total income of a person as a result

GRANULES INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

disallowed without considering the objections and submissions made during re- assessment proceedings. 6. On the facts and in the circumstances of the case, the learned Commissioner of Income-tax (Appeals)-12, Hyderabad erred by confirming penalty proceedings u/s 271(1)(c) initiated by the learned Assessing Officer on the addition. 3 Granules India Limited 7. On the facts

VK WAREHOUSING ENTERPRISES,HYDERABAD vs. DCIT., CIRCLE-6(1), HYDERABAD

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

disallowance of capital expenditure amounting to INR 34,58,38,297. 8. The Hon’ble CIT(A) is erroneous in upholding the levy of interest u/s 234B and penaltyimposed u/s 271(1)(b) of the Act. 9. The Appellant respectfully seeks leave to submit additional factual and legal arguments during the proceedings before Your Honours.” On the other hand

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

271] 4.2.20. In this regard, we wish to submit that the powers of the learned CIT(A) is very wide and co-terminus with the powers of the AO. Page 28 of 34 ITA Nos 508 and others Ascend Telcom Infrastructure P Ltd We wish to draw reference to provision of section 250(4) of the Act as well which

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

271] 4.2.20. In this regard, we wish to submit that the powers of the learned CIT(A) is very wide and co-terminus with the powers of the AO. Page 28 of 34 ITA Nos 508 and others Ascend Telcom Infrastructure P Ltd We wish to draw reference to provision of section 250(4) of the Act as well which

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELCOM INFRASTRUTURE PRIVATE LIMITED , HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

271] 4.2.20. In this regard, we wish to submit that the powers of the learned CIT(A) is very wide and co-terminus with the powers of the AO. Page 28 of 34 ITA Nos 508 and others Ascend Telcom Infrastructure P Ltd We wish to draw reference to provision of section 250(4) of the Act as well which

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

271] 4.2.20. In this regard, we wish to submit that the powers of the learned CIT(A) is very wide and co-terminus with the powers of the AO. Page 28 of 34 ITA Nos 508 and others Ascend Telcom Infrastructure P Ltd We wish to draw reference to provision of section 250(4) of the Act as well which

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELECOM INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

271] 4.2.20. In this regard, we wish to submit that the powers of the learned CIT(A) is very wide and co-terminus with the powers of the AO. Page 28 of 34 ITA Nos 508 and others Ascend Telcom Infrastructure P Ltd We wish to draw reference to provision of section 250(4) of the Act as well which

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. ASCEND TELCOM INFRASTRUTURE PRIVATE LIMITED , HYDERABAD

In the result, the appeal filed by the Revenue is allowed for statistical purposes while the corresponding C

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

271] 4.2.20. In this regard, we wish to submit that the powers of the learned CIT(A) is very wide and co-terminus with the powers of the AO. Page 28 of 34 ITA Nos 508 and others Ascend Telcom Infrastructure P Ltd We wish to draw reference to provision of section 250(4) of the Act as well which

DCIT,CIRCLE-17(1), HYD, HYDERABAD vs. DR. REDDY'S LABOURATORIES LTD., HYD, HYDERABAD

In the result, appeal of the revenue is dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2006-07

Section 271, the requirement of recording of satisfaction and the prevalence of 'mens rea' is still a pre-requisite. (c) It may be noted that all the additions made were a result of issues in respect of which more than one view is possible. It may be noted that there are no disallowances

SYNFOSYS BUSINESS SOLUTIONS LTD., HYDERABAD,HYDERABAD vs. ITO, WARD-3(4), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony(Through Virtual Hearing) Assessment Year:2011-12 Synfosys Business Vs. Income Tax Officer, Solutions Ltd., Ward-3(4), Hyderabad. Hyderabad. Pan: Aafcs 3590 K (Appellant) (Respondent) Assessee By: Shri A. Srinivas Revenue By: Shri Rajat Mitra, Dr Date Of Hearing: 14/09/2020 Date Of Pronouncement: 17/09/2020 Order Per A. Mohan Alankamony, Am.:

section 271(1)(c) of the Act. 6. The brief facts of the case are that assessee is a private limited company engaged in software services, filed his return of income for the AY 2011-12 on 30/09/2011 claiming exemption U/s. 10A of the Act. Subsequently, order was passed U/s. 143(3) of the Act on 30/03/2014 accepting the return

J VITTAL KUMAR, HYD,HYDERABAD vs. ITO, WARD-8(2), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 J. Vittal Kumar, Vs. Income-Tax Officer, Hyderabad. Ward – 8(2), Hyderabad. Pan – Acepj 2097G Appellant Respondent Assessee By: Shri Y. Ratnakar Revenue By: Smt. Neeju Gupta Date Of Hearing: 11/06/2019 Date Of Pronouncement: 31/07/2019 O R D E R

disallowed and added back for which the assessee has accepted. 2.1 Since, the assessee has concealed the income and, furnished inaccurate particulars of his income, the AO issued penalty notice u/s 271(1)(c) and the assessee was asked to file his objections if any. In response to the penalty notice, assessee's AR filed written submissions. After considering