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

171; (g) any order under clause (b) of sub-section (1) or under sub-section (2) or sub- section (3) or sub-section (5) of section 185 in respect of any assessment for the assessment year commencing on or before the 1st day of April, 1992; (h) an order cancelling the registration of a firm under sub-section

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

171; (g) any order under clause (b) of sub-section (1) or under sub-section (2) or sub- section (3) or sub-section (5) of section 185 in respect of any assessment for the assessment year commencing on or before the 1st day of April, 1992; (h) an order cancelling the registration of a firm under sub-section

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

171; (g) any order under clause (b) of sub-section (1) or under sub-section (2) or sub- section (3) or sub-section (5) of section 185 in respect of any assessment for the assessment year commencing on or before the 1st day of April, 1992; (h) an order cancelling the registration of a firm under sub-section

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

171; (g) any order under clause (b) of sub-section (1) or under sub-section (2) or sub- section (3) or sub-section (5) of section 185 in respect of any assessment for the assessment year commencing on or before the 1st day of April, 1992; (h) an order cancelling the registration of a firm under sub-section

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

penalty of Rs.23,62,299/-. 28. Aggrieved, the assessee company assailed the order passed by the AO under section 271(1)(c) of the Act before the CIT(A). As the assessee company had delayed the filing of the appeal before the CIT(A) by 663 days, therefore, the latter rejected the explanation of the assessee company and declined

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

penalty of Rs.23,62,299/-. 28. Aggrieved, the assessee company assailed the order passed by the AO under section 271(1)(c) of the Act before the CIT(A). As the assessee company had delayed the filing of the appeal before the CIT(A) by 663 days, therefore, the latter rejected the explanation of the assessee company and declined

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

penalty of Rs.23,62,299/-. 28. Aggrieved, the assessee company assailed the order passed by the AO under section 271(1)(c) of the Act before the CIT(A). As the assessee company had delayed the filing of the appeal before the CIT(A) by 663 days, therefore, the latter rejected the explanation of the assessee company and declined

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

penalty of Rs.23,62,299/-. 28. Aggrieved, the assessee company assailed the order passed by the AO under section 271(1)(c) of the Act before the CIT(A). As the assessee company had delayed the filing of the appeal before the CIT(A) by 663 days, therefore, the latter rejected the explanation of the assessee company and declined

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERBAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

penalty of Rs.23,62,299/-. 28. Aggrieved, the assessee company assailed the order passed by the AO under section 271(1)(c) of the Act before the CIT(A). As the assessee company had delayed the filing of the appeal before the CIT(A) by 663 days, therefore, the latter rejected the explanation of the assessee company and declined

APMDC SCCL SULIYARI COAL COMPANY LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, the appeals filed by the assessee company are disposed of as under:

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1501, 1514, 1515 & 1529/Hyd/2025 (िनधा"रण वष"/Ay: 2016-17, 2017-18, 2018-19 & 2019-20) Apmdc Sccl Suliyari Coal Vs. Dcit, Company Limited, Circle-1(1), Hyderabad. Hyderabad. Pan: Aalca9755A (Appellant) (Respondent)

penalty of Rs.23,62,299/-. 28. Aggrieved, the assessee company assailed the order passed by the AO under section 271(1)(c) of the Act before the CIT(A). As the assessee company had delayed the filing of the appeal before the CIT(A) by 663 days, therefore, the latter rejected the explanation of the assessee company and declined

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

271. By issuing such notices, the assessment order becomes final. Various courts have held that such assessment orders to be null and void ab- initio. We have carefully considered the submission and case laws relied. In all the case laws relied on by the assessee, the common mistake made by the AO in those assessments were that AO passed

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

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

171 and 172/Hyd/2013, seeking to recall of the said orders u/s 254(2) of the Act. 2. The grounds raised by the assessee in ITA No.1937 and 1938/Hyd/2014 are similar except the amounts involved. Hence, we are reproducing the grounds in ITA No.1937/Hyd/2014 for A.Y. 2005-06 only for the sake of brevity. Madhucon Projects Limited, Hyderabad. “1) The order

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

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

171 and 172/Hyd/2013, seeking to recall of the said orders u/s 254(2) of the Act. 2. The grounds raised by the assessee in ITA No.1937 and 1938/Hyd/2014 are similar except the amounts involved. Hence, we are reproducing the grounds in ITA No.1937/Hyd/2014 for A.Y. 2005-06 only for the sake of brevity. Madhucon Projects Limited, Hyderabad. “1) The order

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

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

171 and 172/Hyd/2013, seeking to recall of the said orders u/s 254(2) of the Act. 2. The grounds raised by the assessee in ITA No.1937 and 1938/Hyd/2014 are similar except the amounts involved. Hence, we are reproducing the grounds in ITA No.1937/Hyd/2014 for A.Y. 2005-06 only for the sake of brevity. Madhucon Projects Limited, Hyderabad. “1) The order

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-3(2), HYDERABAD vs. P SHIVMOHAN REDDY, HYDERABAD

In the result, both the appeals filed by the Revenue are allowed for statistical purposes

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

271(1)(b) was also passed on 21.11.2019 levying penalty of Rs.10,000/-. During the course of assessment proceedings, the Assessing Officer noted that certain incriminating materials were found and seized during the course of search and the statement of Shri P. Shivmohan Reddy i.e., the assessee was recorded in which he accepted that he has been receiving money

PRATHIBA EDUCATIONAL SOCIETY,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(4), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita No.1424/Hyd./2025 िनधा"रण वष"/Assessment Years 2017-2018 Prathiba Educational The Income Tax Officer, Society, Hyderabad. Ward-6(4), Pin – 500 038 Vs. Hyderabad. Pan Aaatp4036B. Pin – 500 001 (Appellant) (Respondent) िनधा""रती "ारा/Assessee By : Ca Sanket Milind Joshi राज" व "ारा/Revenue By : Sri Krishna Moorthy K. Sr. Ar सुनवाई की तारीख/Date Of Hearing: 28.10.2025 घोषणा की तारीख/Pronouncement: 31.10.2025 आदेश/Order Per Vijay Pal Rao:

section 69A of Income Tax Act, 1961, 3 ITA.No.1424/Hyd./2025 when the said deposit amount was available with the appellant as cash on hand. 7. The learned AO and Commissioner of Income Tax (Appeals) ought to have allowed the cash deposits amount of Rs.74,26,500 as the cash deposits are emanated from cash on hand. 8. The appellant

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

171 ITR 390 (Allahabad) (35) is of no help to the revenue inasmuch as that was a case involving penalty under Section 271(1)(c) of the Act. That penalty being impossible for concealment of income consequent to scrutiny assessment ITA No.912/Hyd/2024 23 order under Section 143(3) of the Act, it has no application to the present facts involving

MANTRI COSMOS II OWNERS WELFARE ASSOCIATION,HYDERABAD vs. ACIT., CIRCLE-6(1), HYDERABAD

In the result, both the appeals of the assessee for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.20 & 21/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) Mantri Cosmos Ii Owners Vs. Asstt. Commissioner Of Welfare Association Income Tax, Circle 6(1) Hyderabad Hyderabad Pan:Aaeam1297J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates K Hari Prasad & K Karthik राज" व "ारा/Revenue By:: Smt.M Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/03/2025 घोषणा की तारीख/Pronouncement: 21/03/2025 आदेश/Order

171 ITR 390 (Allahabad) (35) is of no help to the revenue inasmuch as that was a case involving penalty under Section 271(1)(c) of the Act. That penalty being impossible for concealment of income Page 7 of 16 ITA Nos 20 and 21 of 2025 Mantri Cosmos II Owners Welfare Association consequent to scrutiny assessment order under Section