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

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

153A r.w.s 254 of the Act was completed on 30.03.2023 and the action for imposition of penalty under section 271D of the Act has been initiated in the course of assessment proceedings. Therefore, clause (c) of section 275(1)(c) of the Act is applicable, which provides Six months from the end of the month in which the action

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 153A, the return of income filed in response to notice u/s 153A is to be considered as return filed u/s 139, as the Assessing Officer has made assessment on the said return and therefore, the return is to be considered for the purpose of penalty u/s 271

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

153A of the Act on 12.07.2021 assessing the total income at Rs.4,37,12,380/-. 6. The ld.AR submitted that the ld.PCIT had issued the show cause notice dt.10.01.2023 u/s 263 of the Act revising the assessment order as the Assessing Officer has not initiated the penalty u/s 271(1) of the Income Tax Act. 7. In the show cause

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

153A of the Act on 12.07.2021 assessing the total income at Rs.4,37,12,380/-. 6. The ld.AR submitted that the ld.PCIT had issued the show cause notice dt.10.01.2023 u/s 263 of the Act revising the assessment order as the Assessing Officer has not initiated the penalty u/s 271(1) of the Income Tax Act. 7. In the show cause

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.

153A of the Act was concluded on 31/03/2023 and the action for imposition of penalty under section 271DA of the Act has not been initiated in the course of assessment proceedings. Therefore, clause (a) of section 275(1)(c) of the Act is not applicable. Further, clause (b) of section 275(1)(c) of the Act provides Six months from

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.

153A of the Act was concluded on 31/03/2023 and the action for imposition of penalty under section 271DA of the Act has not been initiated in the course of assessment proceedings. Therefore, clause (a) of section 275(1)(c) of the Act is not applicable. Further, clause (b) of section 275(1)(c) of the Act provides Six months from

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

penalty should not be levied u/s 271(1)(c). As per Explanation 1 to Section 271(1)(c), the appellant has failed to offer an explanation regarding the non-disclosure of income in this year, while filing the return u/s 139 and also return u/s 153A

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

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

153A of the Act was concluded on 31/03/2023 and\nthe action for imposition of penalty under section 271DA of the\nAct has not been initiated in the course of assessment\nproceedings. Therefore, clause (a) of section 275(1)(c) of the Act is\nnot applicable. Further, clause (b) of section 275(1)(c) of the Act\nprovides Six months from

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

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

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

153A of the Act was concluded on 31/03/2023 and\nthe action for imposition of penalty under section 271DA of the\nAct has not been initiated in the course of assessment\nproceedings. Therefore, clause (a) of section 275(1)(c) of the Act is\nnot applicable. Further, clause (b) of section 275(1)(c) of the Act\nprovides Six months from

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

penalty provisions of Section 271(1)(c) of the Act. Further, in our understanding, the Hon’ble High Court has not decided the issue with respect to the time frame provided for claiming the deduction as per section 80AC r.w. section 139(1) and Rule 18BBB and Page 31 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

penalty provisions of Section 271(1)(c) of the Act. Further, in our understanding, the Hon’ble High Court has not decided the issue with respect to the time frame provided for claiming the deduction as per section 80AC r.w. section 139(1) and Rule 18BBB and Page 31 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg

NAVAYUGA ENGINEERING COMPANY LIMITED,HYDERABAD vs. ACIT CIRCLE-1(1), HYDERABAD

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

penalty provisions of Section 271(1)(c) of the Act. Further, in our understanding, the Hon’ble High Court has not decided the issue with respect to the time frame provided for claiming the deduction as per section 80AC r.w. section 139(1) and Rule 18BBB and Page 31 of 39 ITA Nos 239 to 241 of 2022 Navayuga Engg

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

153A of the Act admitting the total income and the same was accepted by the Assessing Officer in the assessment proceedings, therefore, it cannot be said that the assessee had submitted inaccurate particulars of income, for which the penalty can be imposed u/s 271(1)(c) of the Act. For the above said purposes, ld.AR had relied upon the decision

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

153A of the Act admitting the total income and the same was accepted by the Assessing Officer in the assessment proceedings, therefore, it cannot be said that the assessee had submitted inaccurate particulars of income, for which the penalty can be imposed u/s 271(1)(c) of the Act. For the above said purposes, ld.AR had relied upon the decision

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

u/s 271(1)(c) of the Act. For the above said purposes, ld.AR had relied upon the decision of Hon’ble Delhi High Court in the case of PCIT Vs. Neeraj Jindal. “22. The second question concerns the interpretation and application of Explanation-5 to Section 271(1)(c) and whether it is attracted in the facts of this case

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

153A of\nthe Act dated 30.12.2019.\n6. The Ld. CIT(A) failed to consider that the AO has not recorded\nsatisfaction for involving penal provisions u/s 271D of the Act and\nthus, the penalty order passed u/s 271D on 23.06.2021 is invalid\nand bad in law.\n7. The Ld. CIT(A) failed to consider that the observations