AURORA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

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

14. The Ld. CIT-DR, Ms. U. Mini Chandran, supporting the order of the Ld. CIT (A) submitted that, there is no merit in the legal ground taken by the assessee challenging the limitation in passing the penalty order under section 271D of the Act, because as per the provisions of section 275(1)(c) of the Act, there

MOOLA PADMAJA,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(2), HYDERABAD

In the result, the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2012-13 Moola Padmaja Vs. Acit,Cc-3(2) 8-1-293/A/74/A 7Th Floor Dwaraka Nagar Colony Aaykar Bhawan Narayanamma Engineering Basheer Bagh College, Raidurg Hyderabad-500 004 Hyderabad-500 008 Pan : Aoipp2482B Assessment Year: 2012-13 Vinod Aerakula Vs Acit,Cc-3(2) B-109, Western Plaza 7Th Floor Hussain Shahwali Darha Aaykar Bhawan Shaikpet, Hyderabad Basheer Bagh Telangana Hyderabad-500 004 Pan : Aoopa5855R (Appellant) (Respondent) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri K.P.R.R.Murthy, Sr.Ar Date Of Hearing: 15.02.2023 Date Of Pronouncement: 22.02.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): The Above Two Appeals Filed By The Respective Assessees Are Directed Against The Separate Orders Dated 31.03.2022 & 27.3.2022 Respectively Of The Learned Cit(A) (Appeals)-11, Hyderabad Relating To Ay 2012-13. Since Identical Grounds Have Been Raised By The Respective Assessees, Therefore, These Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience.

14, 20, 21, 22 and 23 situated at Dargah Hussain Shahwali(v), Serlingampally(M), Ranga Reddy district. The assessee along with other co-owners entered into a land development agreement with M/s. Western Constructions on 03.05.2007. As per the supplementary development agreement dated 26.03.2010 the landlords were supposed to get 40% of the total built up area of 10

VINOD AERUKALA ,HYDERABAD vs. ACIT CENTRAL CIRCLE-3(2), HYDERABAD

In the result, the appeals filed by the respective assessees are dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2012-13 Moola Padmaja Vs. Acit,Cc-3(2) 8-1-293/A/74/A 7Th Floor Dwaraka Nagar Colony Aaykar Bhawan Narayanamma Engineering Basheer Bagh College, Raidurg Hyderabad-500 004 Hyderabad-500 008 Pan : Aoipp2482B Assessment Year: 2012-13 Vinod Aerakula Vs Acit,Cc-3(2) B-109, Western Plaza 7Th Floor Hussain Shahwali Darha Aaykar Bhawan Shaikpet, Hyderabad Basheer Bagh Telangana Hyderabad-500 004 Pan : Aoopa5855R (Appellant) (Respondent) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri K.P.R.R.Murthy, Sr.Ar Date Of Hearing: 15.02.2023 Date Of Pronouncement: 22.02.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): The Above Two Appeals Filed By The Respective Assessees Are Directed Against The Separate Orders Dated 31.03.2022 & 27.3.2022 Respectively Of The Learned Cit(A) (Appeals)-11, Hyderabad Relating To Ay 2012-13. Since Identical Grounds Have Been Raised By The Respective Assessees, Therefore, These Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience.

14, 20, 21, 22 and 23 situated at Dargah Hussain Shahwali(v), Serlingampally(M), Ranga Reddy district. The assessee along with other co-owners entered into a land development agreement with M/s. Western Constructions on 03.05.2007. As per the supplementary development agreement dated 26.03.2010 the landlords were supposed to get 40% of the total built up area of 10

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL CIT, CENTRAL RANGE-2, HYDERABAD

In the result, the appeals filed by the assessee for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 To 2021-22) M/S. Msn Laboratories (P) Ltd Vs. Additional Cit Hyderabad Central Range-2 Pan:Aadcm6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate, But Identical Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad, All Dated 08/10/2025 For The A.Ys 2018-19 To 2021-22 Respectively. Since, Identical Issues Have Been Raised By The Assessee In All These Four Appeals, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

10 in D M Manasvi vs Commissioner of Income Tax (1973) 3 SCC 207 would cast some doubt on the correctness of Grihalakshmi supra. “We are also not impressed by the argument advanced on behalf of the appellant that the proceedings for the imposition of penalty were initiated not by the Income Tax Officer but by the Inspecting Assistant Commissioner

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL. CIT, CENTRAL RANGE-2, HYDERABAD

In the result, the appeals filed by the assessee for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 To 2021-22) M/S. Msn Laboratories (P) Ltd Vs. Additional Cit Hyderabad Central Range-2 Pan:Aadcm6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate, But Identical Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad, All Dated 08/10/2025 For The A.Ys 2018-19 To 2021-22 Respectively. Since, Identical Issues Have Been Raised By The Assessee In All These Four Appeals, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

10 in D M Manasvi vs Commissioner of Income Tax (1973) 3 SCC 207 would cast some doubt on the correctness of Grihalakshmi supra. “We are also not impressed by the argument advanced on behalf of the appellant that the proceedings for the imposition of penalty were initiated not by the Income Tax Officer but by the Inspecting Assistant Commissioner

SRI ADITYA HOMES PRIVATE LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee in ITA

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

10. The assessee had submitted reply to the ld.PCIT, however, the ld.PCIT was not convinced by the submissions made by the assessee and has passed the following directions : “18. In view of all the above, it is held that the objections raised by the assessee vide it's letter dated 17.01.2023 in response to notice u/s. 263 dated

SRI ADITYA HOMES PRIVATE LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee in ITA

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

10. The assessee had submitted reply to the ld.PCIT, however, the ld.PCIT was not convinced by the submissions made by the assessee and has passed the following directions : “18. In view of all the above, it is held that the objections raised by the assessee vide it's letter dated 17.01.2023 in response to notice u/s. 263 dated

SRI RAJA REDDY NALLA,WARANGAL vs. ACIT, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Sri Raja Reddy Nalla Vs. Add. C. I. T. Warangal Central Circle 1(3) Pan:Aaxpn3602Q Hyderabad (Appellant) (Respondent) Assessment Year: 2019-20 Sri Venkateshwar Vs. Dy. C. I. T. Reddy :Pacchica, Warangal Central Circle 1(3) Pan:Ablpp0688B Hyderabad (Appellant) (Respondent) Assessee By: Shri K.C. Devdas, Ca Revenue By: Shri Kprr Murthy Cot(Dr) Date Of Hearing: 19/04/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M The Above Two Appeals Filed By The Respective Assessees Are Directed Against The Separate Orders Dated 11.08.2022 Of The Learned Cit (A)-11, Hyderabad, Relating To A.Y.2019-20. Since Identical Grounds Have Been Raised In These Two Appeals, Therefore, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

271 D of the Act were initiated for violating the provisions of Section 2699SS and penalty order u/s, 271D of the Ac was passed on 07.06.2022 by the Addl. CIT levying a penalty of Rs. 40,00,000/-. The appellant had agreed that he had received Rs. 40,00,000/-in cash as his share of advance towards sale

SRI VENKATESHWAR REDDY PACCHICA,WARANGAL vs. ADDL. COMMISSIONER OF INCOME TAX CENTRAL RANGE1, HYDERABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Sri Raja Reddy Nalla Vs. Add. C. I. T. Warangal Central Circle 1(3) Pan:Aaxpn3602Q Hyderabad (Appellant) (Respondent) Assessment Year: 2019-20 Sri Venkateshwar Vs. Dy. C. I. T. Reddy :Pacchica, Warangal Central Circle 1(3) Pan:Ablpp0688B Hyderabad (Appellant) (Respondent) Assessee By: Shri K.C. Devdas, Ca Revenue By: Shri Kprr Murthy Cot(Dr) Date Of Hearing: 19/04/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M The Above Two Appeals Filed By The Respective Assessees Are Directed Against The Separate Orders Dated 11.08.2022 Of The Learned Cit (A)-11, Hyderabad, Relating To A.Y.2019-20. Since Identical Grounds Have Been Raised In These Two Appeals, Therefore, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

271 D of the Act were initiated for violating the provisions of Section 2699SS and penalty order u/s, 271D of the Ac was passed on 07.06.2022 by the Addl. CIT levying a penalty of Rs. 40,00,000/-. The appellant had agreed that he had received Rs. 40,00,000/-in cash as his share of advance towards sale

SARAT GOPAL BOPPANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.635/Hyd/2022 & Sa No.49/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Sarat Gopal Boppana Vs. Asstt. C. I. T. Hyderabad Central Circle 2(3) Pan:Afcpb8083K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 19/06/2024 घोषणा की तारीख/Pronouncement: 07/08/2024 आदेश/Order

section 271(1)(c) and Explanation 5A provided therein. The learned CIT (A) without appreciating the relevant facts has simply sustained the penalty levied by the Assessing Officer. Thus, we set aside the order passed by the learned CIT (A) and direct the Assessing Officer to delete the penalty levied u/s 271(1)(c) of the I.T. Act, 1961. 14

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, TIRUPATI, TIRUPATI vs. PALLAM REDDY SREELAKSHMI, TIRUPATI

Appeals are dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

14-12-2021 Date of Pronouncement : 04-01-2022 O R D E R PER S.S.GODARA, J.M. : These two Revenue’s appeals for AY.2017-18 arise from the CIT(A)-3, Visakhapatnam’s order(s); both dated 07-10- 2020 passed in appeal Nos.113 & 112 / 2019-20 / CIT(A)-3 / VSP / 2019-20 & 2020-21, involving proceedings u/s.271AAB of the Income

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, TIRUPATI vs. PALAKALA GUNASEKHAR, TIRUPATI

Appeals are dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

14-12-2021 Date of Pronouncement : 04-01-2022 O R D E R PER S.S.GODARA, J.M. : These two Revenue’s appeals for AY.2017-18 arise from the CIT(A)-3, Visakhapatnam’s order(s); both dated 07-10- 2020 passed in appeal Nos.113 & 112 / 2019-20 / CIT(A)-3 / VSP / 2019-20 & 2020-21, involving proceedings u/s.271AAB of the Income

VIJAYAWADA TOLLWAY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal filed by the assessee is

14,77,222 Penalty proceedings u/s 271(1)(c) initiated separately. DY. COMMISSIONER OF SEAL CIRCL (VENUDHAR GODESI, I.R.S) Deputy Commissioner of Income-tax, Circle-17(2), Hyderabad. 8. On perusal of the above, we find that the Ld. AO has merely mentioned that “penalty proceedings u/s 271(1)(c) of the Act initiated separately.” However, there is no recording

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL CIT, CENTRAL RANGE-2, HYDERABAD

14 of 33 he relied upon the decision of the ITAT Benches of Chennai in the case of Sri Sai Balaji Gas Cylinder (P) Ltd VS. Assistant Commissioner of Income Tax (2023) 155 Taxmann.com 319 (Chennai) and also the decision of the Hon'ble Madras High Court in the case of Tvi. Chandro Process vs. DCIT (2025) 173 Taxmann.com

SHAVVA SUDHEER REDDY,HYDERABAD vs. ACIT, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2015-16

section 271(1)(c) read with explanation 5A come into play. Accordingly, I deem this a fit case for levy of penalty u/s 271(1)(c) to the extent of undisclosed investments found during search in the form of seized material mentioned above. The seized material indicate that the assessee invested Rs.6 lakhs towards purchase of property at Kondapur, Hyderabad

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL CIT, CENTRAL RANGE-2 , HYDERABAD

14 of 33 he relied upon the decision of the ITAT Benches of Chennai in the case of Sri Sai Balaji Gas Cylinder (P) Ltd VS. Assistant Commissioner of Income Tax (2023) 155 Taxmann.com 319 (Chennai) and also the decision of the Hon'ble Madras High Court in the case of Tvi. Chandro Process vs. DCIT (2025) 173 Taxmann.com

GUNTI PRASAD ,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

10. In all these appeals, the issue in dispute is against the penalty levied u/s 271(1)(c) of the Act. 11. To dispose of these appeals, we refer to the facts from ITA No. 2360/Hyd/2018 and the decision taken in this appeal shall mutatis-mutandis apply to all other appeals as well. 12. Briefly the facts are that

GUNTI ANIL KUMAR ,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

10. In all these appeals, the issue in dispute is against the penalty levied u/s 271(1)(c) of the Act. 11. To dispose of these appeals, we refer to the facts from ITA No. 2360/Hyd/2018 and the decision taken in this appeal shall mutatis-mutandis apply to all other appeals as well. 12. Briefly the facts are that