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

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

26,19,39,954/- under Section 271D of the Income Tax Act, 1961. The relevant portion of penalty order reads as under : “10. Later, the assessee filed submission on 14.06.2024 & 24.06.2024. The para wise submission is discussed as under: 1. Brief facts of the case and issue is pending for adjudication before Higher forum: The Assessing Officer in the original

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.

10. Referring to the decision of Hon’ble AP High Court in the case of Chennakesava Pharmaceuticals vs. CIT reported in 349 ITR 196, he submitted that the Hon’ble High Court in the said decision has held that the AO should, before imposing penalty, record in the assessment order his satisfaction that the assessee had either concealed the income

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.

10. Referring to the decision of Hon’ble AP High Court in the case of Chennakesava Pharmaceuticals vs. CIT reported in 349 ITR 196, he submitted that the Hon’ble High Court in the said decision has held that the AO should, before imposing penalty, record in the assessment order his satisfaction that the assessee had either concealed the income

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.

10. Referring to the copy of the assessment order, he submitted that there is no satisfaction recorded by the Assessing Officer for initiation of penalty proceedings u/s 271D of the I.T. Act. Referring to the decision of the Hon'ble jurisdictional High Court in the case of Srinivasa Reddy Reddeppagari vs. Jt. CIT vide writ petition No.44285 of 2022 dated

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.

10. Referring to the copy of the assessment order, he submitted that there is no satisfaction recorded by the Assessing Officer for initiation of penalty proceedings u/s 271D of the I.T. Act. Referring to the decision of the Hon'ble jurisdictional High Court in the case of Srinivasa Reddy Reddeppagari vs. Jt. CIT vide writ petition No.44285 of 2022 dated

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

In the result, the appeals filed by the assessee for the\nΑ

10 in D M Manasvi vs\nCommissioner of Income Tax (1973) 3 SCC 207 would\ncast some doubt on the correctness of Grihalakshmi supra.\n\"We are also not impressed by the argument\nadvanced on behalf of the appellant that the\nproceedings for the imposition of penalty were\ninitiated not by the Income Tax Officer but by\nthe Inspecting Assistant

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

10 in D M Manasvi vs\nCommissioner of Income Tax (1973) 3 SCC 207 would\ncast some doubt on the correctness of Grihalakshmi supra.\n\"We are also not impressed by the argument\nadvanced on behalf of the appellant that the\nproceedings for the imposition of penalty were\ninitiated not by the Income Tax Officer but by\nthe Inspecting Assistant

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) had been initiated when it is clear that the penalty has been initiated for "concealment of particulars of income". In view of the same, the ground no.2 is dismissed accordingly. Further, with regards to facts of the case, the appellant had invested Rs. 6,00,000/- towards interiors and purchase of a villa bearing

DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD vs. HINDUPUR BIO-ENERGY PVT. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is dismissed, and the appeal of Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2011-12 Hindupur Bio-Energy Vs. The Deputy Commissioner Private Limited, Of Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessment Year: 2011-12 The Deputy Commissioner Hindupur Bio-Energy Of Income Tax, Private Limited, Circle 2(2), Hyderabad. Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessee By: Shri M. Chandramouleswara Rao, C.A. Revenue By: Shri L.V. Bhaskara Reddy, Cit-Dr Date Of Hearing: 11.12.2023 Date Of Pronouncement: 21.12.2023

10. The next ground raised by the assessee before us is that the penalty was imposed merely based on the statement of K. Vijay Kumar who happens to be associated with the assessee company. Infact, the above said statement of K. Vijay Kumar was subsequently confirmed by the Director K. Sudhakar in his statement dt.19.09.2013, wherein he, in response

HINDUPUR BIO-ENERGY PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee is dismissed, and the appeal of Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2011-12 Hindupur Bio-Energy Vs. The Deputy Commissioner Private Limited, Of Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessment Year: 2011-12 The Deputy Commissioner Hindupur Bio-Energy Of Income Tax, Private Limited, Circle 2(2), Hyderabad. Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessee By: Shri M. Chandramouleswara Rao, C.A. Revenue By: Shri L.V. Bhaskara Reddy, Cit-Dr Date Of Hearing: 11.12.2023 Date Of Pronouncement: 21.12.2023

10. The next ground raised by the assessee before us is that the penalty was imposed merely based on the statement of K. Vijay Kumar who happens to be associated with the assessee company. Infact, the above said statement of K. Vijay Kumar was subsequently confirmed by the Director K. Sudhakar in his statement dt.19.09.2013, wherein he, in response

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

10 as under:\n\"6.\nWe have considered the rival submissions as well as\nthe relevant material on record. There is no dispute that the alleged\ncash of Rs.7,82,500/- was received by the assessee as part of the\nsale consideration on transfer of the immovable property along\nwith the co-owner. The JCIT has levied the penalty u/sec.271D

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

10 as under:\n\"6.\nWe have considered the rival submissions as well as\nthe relevant material on record. There is no dispute that the alleged\ncash of Rs.7,82,500/- was received by the assessee as part of the\nsale consideration on transfer of the immovable property along\nwith the co-owner. The JCIT has levied the penalty u/sec.271D

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

In the result, three appeals i

10 as under:\n"6.\nWe have considered the rival submissions as well as\nthe relevant material on record. There is no dispute that the alleged\ncash of Rs.7,82,500/- was received by the assessee as part of the\nsale consideration on transfer of the immovable property along\nwith the co-owner. The JCIT has levied the penalty u/sec.271D

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

10 as under:\n\"6.\nWe have considered the rival submissions as well as\nthe relevant material on record. There is no dispute that the alleged\ncash of Rs.7,82,500/- was received by the assessee as part of the\nsale consideration on transfer of the immovable property along\nwith the co-owner. The JCIT has levied the penalty u/sec.271D