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.

section 271(1)(c) of the Act and sent a reply on which the penalty was levied. Therefore, no prejudice was caused to the assessee by the defective nature of the notice as he had full opportunity before the ITO to set out his defense against the levy of penalty u/s. 271(1)(c) of the I.T.Act. 20

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

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

20. The assessee had also relied upon the decision of the Hon'ble Delhi High Court in the case of Pr. CIT vs. Rishikesh Buildcon (P) Ltd (Supra). The Hon’ble Delhi High Court, in light of penalty levied u/s 271D of the Act and the limitation provided u/s 275(1)(c) of the Act, held as under

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

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

20. The assessee had also relied upon the decision of the Hon'ble Delhi High Court in the case of Pr. CIT vs. Rishikesh Buildcon (P) Ltd (Supra). The Hon’ble Delhi High Court, in light of penalty levied u/s 271D of the Act and the limitation provided u/s 275(1)(c) of the Act, held as under

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

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

20. The assessee had also relied upon the decision of the Hon'ble Delhi High Court in the case of Pr. CIT vs. Rishikesh Buildcon (P) Ltd (Supra). The Hon’ble Delhi High Court, in light of penalty levied u/s 271D of the Act and the limitation provided u/s 275(1)(c) of the Act, held as under

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.

20. The assessee claims that the penalty order is invalid in law as the same is time barred. Admittedly, in the present case, the penalty proceedings were triggered from the A.O with a reference to the Jt. CIT for taking necessary action for imposition of penalty under section 271DA of the Act. The A.O had sent information regarding the violation

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.

20. The assessee claims that the penalty order is invalid in law as the same is time barred. Admittedly, in the present case, the penalty proceedings were triggered from the A.O with a reference to the Jt. CIT for taking necessary action for imposition of penalty under section 271DA of the Act. The A.O had sent information regarding the violation

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.

20,000/- as per the Section 269SS of the IT Act, penalty proceedings u/s. 271D were initiated for violating the provisions Page 2 of 25 ITA No 520 & 522 of 2022 Sri Raja Reddy Nalla & Venkateshwar Reddy Pacchica of Section 269SS and penalty order u/s. 271D of the Act was passed on 07.06.2022 levying a penalty

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.

20,000/- as per the Section 269SS of the IT Act, penalty proceedings u/s. 271D were initiated for violating the provisions Page 2 of 25 ITA No 520 & 522 of 2022 Sri Raja Reddy Nalla & Venkateshwar Reddy Pacchica of Section 269SS and penalty order u/s. 271D of the Act was passed on 07.06.2022 levying a penalty

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

u/s 263 of the Act on 22.02.2023 and therefore, the order passed by the Assessing Officer, pursuant to the direction of ld.PCIT would not be barred by limitation. 20. The second argument raised by the ld.AR for the assessee during the course of oral and written submissions that the ld.PCIT cannot direct for the initiation of penalty to the Assessing

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

u/s 263 of the Act on 22.02.2023 and therefore, the order passed by the Assessing Officer, pursuant to the direction of ld.PCIT would not be barred by limitation. 20. The second argument raised by the ld.AR for the assessee during the course of oral and written submissions that the ld.PCIT cannot direct for the initiation of penalty to the Assessing

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

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

section 271 would not\nshow that the proceedings in such a case\ncannot be initiated by the Income Tax Officer.\nThe Income Tax Officer in such an event can\nrefer the case to the Inspecting Assistant\nCommissioner after initiating the proceedings.\nIt would, indeed, be the satisfaction\nIncome Tax Officer in the course of the\nof the\nPage 20

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

section 271 would not\nshow that the proceedings in such a case\ncannot be initiated by the Income Tax Officer.\nThe Income Tax Officer in such an event can\nrefer the case to the Inspecting Assistant\nCommissioner after initiating the proceedings.\nIt would, indeed, be the satisfaction\nof the\nIncome Tax Officer in the course\nof the\nPage 20

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, TIRUPATI, TIRUPATI vs. PALLAM REDDY SREELAKSHMI, TIRUPATI

Appeals are dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 271AAB(3) of the Act. In the notice issued to the assessee there is no mention about the various conditions provided u/s 271 AAB of the Act relating to levy of penalty @ 10% or 20

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, TIRUPATI vs. PALAKALA GUNASEKHAR, TIRUPATI

Appeals are dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

Section 271AAB(3) of the Act. In the notice issued to the assessee there is no mention about the various conditions provided u/s 271 AAB of the Act relating to levy of penalty @ 10% or 20

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

20,000 or more for any\ntransaction in immovable property. It is also proposed to provide a\npenalty of an equal amount in case of contravention of such\nprovisions.\nThe Memorandum forming part of Finance Bill, 201.5\nhighlighting the intention of the amendment is captured\nbelow:\nB. MEASURES TO CURB BLACK MONEY\nMode of taking or accepting certain loans, deposits

GUNTI PRASAD (HUF),HYDERABAD vs. INCOME TAX OFFICER, WARD-9(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 271(1)(c) Explanation 5A, when the same will be applied as quoted supra. Therefore, respectfully following the above judgment of the Hon’ble Supreme Court, we direct the AO to delete the penalty levied u/s 271(1)(c) Explanation 5A. Accordingly, the grounds raised by the assessee on this are allowed. 18. In the result, appeal

GUNTI ANIL KUMAR ,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 271(1)(c) Explanation 5A, when the same will be applied as quoted supra. Therefore, respectfully following the above judgment of the Hon’ble Supreme Court, we direct the AO to delete the penalty levied u/s 271(1)(c) Explanation 5A. Accordingly, the grounds raised by the assessee on this are allowed. 18. In the result, appeal

GUNTI PRASAD ,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 271(1)(c) Explanation 5A, when the same will be applied as quoted supra. Therefore, respectfully following the above judgment of the Hon’ble Supreme Court, we direct the AO to delete the penalty levied u/s 271(1)(c) Explanation 5A. Accordingly, the grounds raised by the assessee on this are allowed. 18. In the result, appeal

GUNTI ASHWIN KUMAR ,HYDERABAD vs. INCOME TAX OFFICER, WARD-9(2), HYDERABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahusl.

section 271(1)(c) Explanation 5A, when the same will be applied as quoted supra. Therefore, respectfully following the above judgment of the Hon’ble Supreme Court, we direct the AO to delete the penalty levied u/s 271(1)(c) Explanation 5A. Accordingly, the grounds raised by the assessee on this are allowed. 18. In the result, appeal