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19 results for “penalty u/s 271”+ Section 145(2)clear

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Key Topics

Section 80I19Section 142(1)14Section 143(3)12Section 13211Section 143(2)10Addition to Income10Section 133A8Section 1278Survey u/s 133A

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 57/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

8
Section 1476
Deduction5
Disallowance5

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 53/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 54/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

D S R INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 51/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 64/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 56/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

D S R INFRASTRUCTUREPRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE- 1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 49/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

DCIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 50/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

271 (SC). 2. Hon'ble CIT (A)'s kind attention is invited to apportionment of alleged on-money and found noted in the loose slip impounded in the premises of DSR. It is submitted that when the receipt of on money is doubt and appellant denied the same in the course of assessment proceeding the question of apportionment does

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

ITA 1937/HYD/2014[2005-06]Status: DisposedITAT Hyderabad02 Mar 2023AY 2005-06

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

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Jeevan Lal Lavidiya
Section 132Section 153ASection 254(2)Section 801ASection 80I

2. The Assistant Commissioner of Income Tax, Hyderabad has erred while passing order u/s 143(3) r.w.s. 263 of M/s. Madhucon Projects Ltd., on the basis of orders passed by CIT(Central), u/s 263 and same was considered by the CIT(A) – VII by arriving appellants income as 10% instead of the estimating the method prescribed by the assessee

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

ITA 1938/HYD/2014[2006-07]Status: DisposedITAT Hyderabad02 Mar 2023AY 2006-07

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

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Jeevan Lal Lavidiya
Section 132Section 153ASection 254(2)Section 801ASection 80I

2. The Assistant Commissioner of Income Tax, Hyderabad has erred while passing order u/s 143(3) r.w.s. 263 of M/s. Madhucon Projects Ltd., on the basis of orders passed by CIT(Central), u/s 263 and same was considered by the CIT(A) – VII by arriving appellants income as 10% instead of the estimating the method prescribed by the assessee

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

ITA 1326/HYD/2015[2005-06]Status: DisposedITAT Hyderabad02 Mar 2023AY 2005-06

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

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Jeevan Lal Lavidiya
Section 132Section 153ASection 254(2)Section 801ASection 80I

2. The Assistant Commissioner of Income Tax, Hyderabad has erred while passing order u/s 143(3) r.w.s. 263 of M/s. Madhucon Projects Ltd., on the basis of orders passed by CIT(Central), u/s 263 and same was considered by the CIT(A) – VII by arriving appellants income as 10% instead of the estimating the method prescribed by the assessee

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14
Section 145Section 92BSection 92C

145 of the Act. 1.3. Ought to have appreciated the fact that the outstanding receivables are accrued from the sale of services rendered to the AE during the normal course of business and hence it cannot be equated to the term 'capital financing' as interpreted in section 92B of the Act. 1.4. Ought to have appreciated the fact that

SKANDA BUILDERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

ITA 530/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

penalties. However, this argument fails to hold weight as during\n\nITA.Nos.514 to 539/Hyd./2025,\nAnd ITA.Nos.308 to 311/Hyd./2025.\n\n40\n\nthe search conducted under Section 132 of the Income Tax Act, the\nManaging Director and Tax Consultant of the appellant, made key\nadmissions acknowledging discrepancies in income reporting.\nThese admissions pertained to unrecorded cash transactions

SURESH KUMAR REDDY KRISHNAPURAM,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

ITA 539/HYD/2025[2022-23]Status: DisposedITAT Hyderabad20 Aug 2025AY 2022-23

Penalty u/s.270A of the Act is initiated separately for non-reporting of income.\n\n9. Aggrieved by the assessment order, the assessee preferred appeal before the learned CIT(A). Before the learned CIT(A), the assessee challenged the rejection of books of accounts and estimation of 14% profit on disclosed\n\nturnover and also estimation of 18% profit on suppressed

MAHENDER REDDY GANJI,WARANGAL vs. INCOME TAX OFFICER, WARD-1, WARANGAL

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

ITA 240/HYD/2024[2016-2017]Status: DisposedITAT Hyderabad02 Apr 2024AY 2016-2017

Bench: Shri Laliet Kumarassessment Year: 2016-17 Mahender Reddy Ganji, Vs. The Income Tax Officer, House No.1-600/4, Near Ward – 1, Petrol Pump, Upparapalle, Warangal, Kesamudram, Warangal, Hanamkonda. Telangana. Pan : Bglpg6211P. (Appellant) (Respondent) Assessee By: Shri Pradeep Raj Kuna, C.A. Revenue By: Shri Mookambikeyan, Sr.Ar Date Of Hearing: 02.04.2024 Date Of Pronouncement: 02.04.2024

For Appellant: Shri Pradeep Raj Kuna, C.AFor Respondent: Shri Mookambikeyan, Sr.AR
Section 139Section 142(1)Section 145(3)Section 147Section 148Section 271(1)(c)

section 145(3) of the Act. Therefore, considering the nature of business and deficiency in details maintained by the assessee, the total income of the assessee was estimated @ 8% of the total turn over of Rs. 2,01,11,181/-. Accordingly, a show cause notice was issued to the assessee. In response, assessee submitted that he was running a wholesale

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, MADHAPUR

In the result, all the appeals of the Revenue are dismissed

ITA 688/HYD/2024[2018-19]Status: DisposedITAT Hyderabad11 Feb 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 80I

271 / Hyd / 2011, dated 07.09.2012 is borne in mind wherein it was held: “……. The Assessing Officer has to see whether the assessee carried on contract for sale or contract for sale and the applicability of Explanation below Section 80IA(13) of the Act. The Assessing Officer is directed to examine the terms of contract including the nature of obligations

M/S KANTAR GDC INDIA PVT. LTD. (FORMERLY TNS INDIA PVT LTD),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2261/HYD/2017[2013-14]Status: HeardITAT Hyderabad03 Jun 2024AY 2013-14

Bench: Shri Mahavir Singh & Shri Manjunatha, G.आ.अपी.सं /Ita No.2261/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2013-14) M/S. Kantar Gdc India (P) Vs. Dy. C. I. T. Ltd (Formerly Tns India (P) Circle 2(2) Ltd, Hyderabad Hyderabad Pan:Aabcn2278F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Harpreet Singh Ajmani राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order

For Appellant: Advocate Harpreet Singh AjmaniFor Respondent: : Shri Shiva Sewak, CIT(DR)
Section 143(3)Section 144C(5)Section 271(1)(c)

penalty proceedings u/s 271(1)(c), 271AA, 271BA of the Act. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 3. Facts of the case, in brief, are that the assessee company is engaged

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, HYDERABAD

In the result, all the appeals of the Revenue are dismissed

ITA 682/HYD/2024[2017-18]Status: DisposedITAT Hyderabad11 Feb 2025AY 2017-18
For Appellant: Shri S. Ramarao, AdvocateFor Respondent: \nMs. M. Narmada, CIT-DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 80I

271 / Hyd / 2011, dated 07.09.2012 is\nborne in mind wherein it was held:\n“....... The Assessing Officer has to see whether the assessee carried on\ncontract for sale or contract for sale and the applicability of Explanation\nbelow Section 80IA(13) of the Act. The Assessing Officer is directed to\nexamine the terms of contract including the nature of obligations

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

ITA 1191/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16
For Appellant: \nShri M.V. Prasad, CAFor Respondent: \nMs. U. Mini Chandran
Section 143(3)Section 147Section 148Section 250

2,49,54,091/- to the\nreturned income of the assessee company and vide his order passed\nunder section 147 r.w.s 144B of the Act, dated 28/03/2022, determined\nthe income of the assessee company at Rs. 111,71,48,621/-.\n8. Aggrieved, the assessee company carried the matter in appeal\nbefore the CIT(A). As the assessee company, despite having