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.

147 of the I.T.Act on 09.12.2019 accepting the returned income of Rs.1,84,41,136/-. 4. Subsequently, the AO initiated penalty proceedings u/s. 271(1)(c) of the I.T.Act and asked the assessee to explain as to why penalty should not be levied u/s. 271(1)(c) of the I.T.Act submitted that he has neither concealed the income nor submitted

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.

147 Taxmann.com 220 (Del.). The assessee had also relied upon the decision of the ITAT Hyderabad Benches in the case of M/s. Sireesha Pochareddy in ITA No.1270/Hyd/2024, dated 12/093/2025. 11. The learned Counsel for the assessee, referring to ground nos. 6, 7 and 8 of the assessee’s appeal submitted that the penalty levied under section 271DA

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.

147 Taxmann.com 220 (Del.). The assessee had also relied upon the decision of the ITAT Hyderabad Benches in the case of M/s. Sireesha Pochareddy in ITA No.1270/Hyd/2024, dated 12/093/2025. 11. The learned Counsel for the assessee, referring to ground nos. 6, 7 and 8 of the assessee’s appeal submitted that the penalty levied under section 271DA

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

In the result, the appeal filed by the assessee is

147 dated 05.12.2019 6,14,77,222 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

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

147 Taxmann.com 220 (Del.). The assessee had also relied upon the decision of the ITAT Hyderabad Benches in the case of M/s. Sireesha Pochareddy in ITA No.1270/Hyd/2024, dated 12/093/2025. 11. The learned Counsel for the assessee, referring to ground nos. 6, 7 and 8 of the assessee's appeal submitted that the penalty levied under section 271DA

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

147 Taxmann.com 220 (Del.). The assessee had also relied upon the decision of the ITAT Hyderabad Benches in the case of M/s. Sireesha Pochareddy in ITA No.1270/Hyd/2024, dated 12/093/2025. 11. The learned Counsel for the assessee, referring to ground nos. 6, 7 and 8 of the assessee's appeal submitted that the penalty levied under section 271DA

KAVERI POLYMERS,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee is dismissed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147, section 148, section 149, section 151 and section 153, in the case of a person68 where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE-1(3),, HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147, section 148, section 149, section 151 and section 153, in the case of a person68 where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within

KAVERI INFRA PROJECT PVT LTD,WARANGAL vs. DCIT, CENTRAL CIRCLE -1(3), HYDERABAD

In the result, the appeal of assessee in ITA

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

147, section 148, section 149, section 151 and section 153, in the case of a person68 where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within

SOMIREDDY SUDHAKAR REDDY,IBRAHIMPATNAM vs. ITO., WARD-9(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1505/Hyd/2025 Assessment Year 2017-2018 Somireddy Sudhakar The Income Tax Officer, Reddy, Ibrahimpatnam Vs. Ward-9(1), Pin -501 506. R R Dist. Hyderabad. Pan Bghps3108R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Mohd. Afzal, Advocate राज" व "ारा /Revenue By: Sri Abhinav Pittal, Sr. Ar

271(1)(c) of the Act. Thus, In so far as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied.” 10. Thus, the Hon’ble Supreme Court has affirmed the view of the Hon’ble High Court that in absence of satisfaction recorded regarding the penalty proceedings u/s 271E

MOHHAMAD WAJAHAT ALI KHAN,HYDERABAD vs. ITO, (INT TXNT)-1, HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.532 To 534/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2016-17& 2017-18) Shri Mohd. Wajahat Ali Vs. Income Tax Officer Khan (International Taxation)-1 Hyderabad Hyderabad Pan:Eampk7060N (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: 21/05/2024 घोषणा की तारीख/Pronouncement: 21/05/2024

147 of the I.T. Act, 1961 for both the A.Ys and made addition towards cash paid for purchase of property u/s 69A of the I.T. Act, 1961. 3. Thereafter, the Assessing Officer initiated penalty proceedings u/s 271F of the I.T. Act, 1961 for A.Y 2016-17 and 2017-18 and has also initiated penalty proceedings u/s 271

MOHHAMAD WAJAHAT ALI KHAN,HYDERABAD vs. ITO, (INT TXNT)-1, HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.532 To 534/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2016-17& 2017-18) Shri Mohd. Wajahat Ali Vs. Income Tax Officer Khan (International Taxation)-1 Hyderabad Hyderabad Pan:Eampk7060N (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: 21/05/2024 घोषणा की तारीख/Pronouncement: 21/05/2024

147 of the I.T. Act, 1961 for both the A.Ys and made addition towards cash paid for purchase of property u/s 69A of the I.T. Act, 1961. 3. Thereafter, the Assessing Officer initiated penalty proceedings u/s 271F of the I.T. Act, 1961 for A.Y 2016-17 and 2017-18 and has also initiated penalty proceedings u/s 271

MOHHAMAD WAJAHAT ALI KHAN,HYDERABAD vs. ITO, (INT TXNT)-1, HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.532 To 534/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2016-17& 2017-18) Shri Mohd. Wajahat Ali Vs. Income Tax Officer Khan (International Taxation)-1 Hyderabad Hyderabad Pan:Eampk7060N (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: 21/05/2024 घोषणा की तारीख/Pronouncement: 21/05/2024

147 of the I.T. Act, 1961 for both the A.Ys and made addition towards cash paid for purchase of property u/s 69A of the I.T. Act, 1961. 3. Thereafter, the Assessing Officer initiated penalty proceedings u/s 271F of the I.T. Act, 1961 for A.Y 2016-17 and 2017-18 and has also initiated penalty proceedings u/s 271

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO ,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION) , NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

u/s 172 of the Act either before the Commissioner of Income Tax (Appeals) or before the Tribunal. He had drawn our attention to section 246 of the I.T. Act which provides as under : “Appealable orders. 246. (1) Subject to the provisions of sub-section (2), any assessee aggrieved by any of the following orders of an Assessing Officer (other than

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

u/s 172 of the Act either before the Commissioner of Income Tax (Appeals) or before the Tribunal. He had drawn our attention to section 246 of the I.T. Act which provides as under : “Appealable orders. 246. (1) Subject to the provisions of sub-section (2), any assessee aggrieved by any of the following orders of an Assessing Officer (other than

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

u/s 172 of the Act either before the Commissioner of Income Tax (Appeals) or before the Tribunal. He had drawn our attention to section 246 of the I.T. Act which provides as under : “Appealable orders. 246. (1) Subject to the provisions of sub-section (2), any assessee aggrieved by any of the following orders of an Assessing Officer (other than

PACC CONTAINER LINE PTE LIMITED,NELLOR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

u/s 172 of the Act either before the Commissioner of Income Tax (Appeals) or before the Tribunal. He had drawn our attention to section 246 of the I.T. Act which provides as under : “Appealable orders. 246. (1) Subject to the provisions of sub-section (2), any assessee aggrieved by any of the following orders of an Assessing Officer (other than

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

u/s 172 of the Act either before the Commissioner of Income Tax (Appeals) or before the Tribunal. He had drawn our attention to section 246 of the I.T. Act which provides as under : “Appealable orders. 246. (1) Subject to the provisions of sub-section (2), any assessee aggrieved by any of the following orders of an Assessing Officer (other than

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. B.RAMALINGA RAJU, HYDERABAD

In the result, the appeal of Revenue in ITA No

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

penalty proceedings under section 271(1)(c) of the Act. 22. Aggrieved by the order of the Assessing Officer, the assessee filed an appeal before the Ld. CIT(A), who granted part relief by deleting the addition of Rs.1122 crores by observing as under : “7.2. I have considered the assessment order, order u/s.263 passed by the TT, the submissions