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

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

26,19,39,954/- under Section 271D of the Income Tax Act, 1961. The relevant portion of penalty order reads as under : “10. Later, the assessee filed submission on 14.06.2024 & 24.06.2024. The para wise submission is discussed as under: 1. Brief facts of the case and issue is pending for adjudication before Higher forum: The Assessing Officer in the original

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 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended. On the basis of such proceedings, no penalty could be imposed to the assessee. s) Taking up of penalty proceedings on one limb and finding the assessee guilty of another

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.

Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended. On the basis of such proceedings, no penalty could be imposed to the assessee. s) Taking up of penalty proceedings on one limb and finding the assessee guilty of another

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.

271 would not show that the proceedings in such a case cannot be initiated by the Income Tax Officer. The Income Tax Officer in such an event can refer the case to the Inspecting Assistant Commissioner after initiating the proceedings. It would, indeed, be the satisfaction of the Income Tax Officer in the course of the Page

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.

271 would not show that the proceedings in such a case cannot be initiated by the Income Tax Officer. The Income Tax Officer in such an event can refer the case to the Inspecting Assistant Commissioner after initiating the proceedings. It would, indeed, be the satisfaction of the Income Tax Officer in the course of the Page

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”. In our view, the above said finding is self-contradictory, as the ld.PCIT himself records that PCIT has the power to record the satisfaction and impose the penalty. In the present case, the ld.PCIT has not recorded satisfaction in the impugned order nor he had initiated and imposed the penalty himself. Quite contrary

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”. In our view, the above said finding is self-contradictory, as the ld.PCIT himself records that PCIT has the power to record the satisfaction and impose the penalty. In the present case, the ld.PCIT has not recorded satisfaction in the impugned order nor he had initiated and imposed the penalty himself. Quite contrary

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(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied. These appeals are, accordingly, dismissed. 24. Reverting back to the facts of the present case, we find that petitioner had submitted reply to the show cause notice on 02.06.2022. In his reply

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(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied. These appeals are, accordingly, dismissed. 24. Reverting back to the facts of the present case, we find that petitioner had submitted reply to the show cause notice on 02.06.2022. In his reply

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

section 271(1\(c) had been initiated when it is clear that the penalty has been initiated for "concealment of particulars of income". In view of the same, the ground no.2 is dismissed accordingly. Further, with regards to facts of the case, the appellant had invested Rs. 6,00,000/- towards interiors and purchase of a villa bearing

DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD vs. HINDUPUR BIO-ENERGY PVT. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is dismissed, and the appeal of Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2011-12 Hindupur Bio-Energy Vs. The Deputy Commissioner Private Limited, Of Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessment Year: 2011-12 The Deputy Commissioner Hindupur Bio-Energy Of Income Tax, Private Limited, Circle 2(2), Hyderabad. Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessee By: Shri M. Chandramouleswara Rao, C.A. Revenue By: Shri L.V. Bhaskara Reddy, Cit-Dr Date Of Hearing: 11.12.2023 Date Of Pronouncement: 21.12.2023

u/s. 148, the assessee would not have filed the return of income, especially considering the past conduct of the assessee and therefore, it is a clear case of concealment of income as per Explanation 3 to section 271(1)(c) of the I.T. Act. Therefore, penalty in our opinion was rightly levied by the AO and sustained by the ld.CIT

HINDUPUR BIO-ENERGY PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee is dismissed, and the appeal of Revenue is allowed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2011-12 Hindupur Bio-Energy Vs. The Deputy Commissioner Private Limited, Of Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessment Year: 2011-12 The Deputy Commissioner Hindupur Bio-Energy Of Income Tax, Private Limited, Circle 2(2), Hyderabad. Hyderabad. Pan : Aabch0124J. (Appellant) (Respondent / Cross-Appellant) Assessee By: Shri M. Chandramouleswara Rao, C.A. Revenue By: Shri L.V. Bhaskara Reddy, Cit-Dr Date Of Hearing: 11.12.2023 Date Of Pronouncement: 21.12.2023

u/s. 148, the assessee would not have filed the return of income, especially considering the past conduct of the assessee and therefore, it is a clear case of concealment of income as per Explanation 3 to section 271(1)(c) of the I.T. Act. Therefore, penalty in our opinion was rightly levied by the AO and sustained by the ld.CIT

ACIT, CENTRAL CIRCLE-2(4), HYDERABAD vs. BAPU REDDY JALA , NIZAMABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2019-20 Acit, Central Circle 2(4) Vs. Shri Bapu Reddy Jala Hyderabad Nizamabad Pan:Aabci9355A (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao, Ca Revenue By: Shri Kumar Aditya, Dr Date Of Hearing: 12/06/2023 Date Of Pronouncement: 15/06/2023 Order Per Laliet Kumar, J.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.08.2022 Of The Learned Cit (A)-12, Hyderabad Relating To A.Y. 2019-20. 2. The Revenue Has Raised The Following Grounds Of Appeal: "1. The Ld. Cit(Appeals) Erred Both In Law & On Facts Of The Case In Granting Relief To The Assessee. 2. The Ld. Cit(A) Erred In Law By Allowing The Assessee'S Appeal The Assessment Order Passed U/S. 153A Of The It Act, 1961 Dated 29.09.2021 Stating That The Sum Of Rs.75,00,000/- Not To Be Treated As Unexplained Income Of The Assessee. 3. The Ld. Cita) Erred In Law By Allowing The Assessee'S Appeal The Assessment Order Passed U/S. 271D Of The It Act, 1961 Dated 01.06.2021

271(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied. These appeals are, accordingly, dismissed. Page 13 of 15 ITA No.606 of 2022 Bapu Reddy Jala 24. Reverting back to the facts of the present case, we find that petitioner had submitted

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) would not apply to proceedings u/s 153C of the Act. 15.3 Finally, the ld. AR of the assessee submitted that levy of penalty u/s 271(1)(c) read with Explanation 5A is invalid, without jurisdiction, bad in law and must be deleted. He relied on the following case law: 1. Heval Navinbhai Patel

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) would not apply to proceedings u/s 153C of the Act. 15.3 Finally, the ld. AR of the assessee submitted that levy of penalty u/s 271(1)(c) read with Explanation 5A is invalid, without jurisdiction, bad in law and must be deleted. He relied on the following case law: 1. Heval Navinbhai Patel

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) would not apply to proceedings u/s 153C of the Act. 15.3 Finally, the ld. AR of the assessee submitted that levy of penalty u/s 271(1)(c) read with Explanation 5A is invalid, without jurisdiction, bad in law and must be deleted. He relied on the following case law: 1. Heval Navinbhai Patel

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) would not apply to proceedings u/s 153C of the Act. 15.3 Finally, the ld. AR of the assessee submitted that levy of penalty u/s 271(1)(c) read with Explanation 5A is invalid, without jurisdiction, bad in law and must be deleted. He relied on the following case law: 1. Heval Navinbhai Patel

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) would not apply to proceedings u/s 153C of the Act. 15.3 Finally, the ld. AR of the assessee submitted that levy of penalty u/s 271(1)(c) read with Explanation 5A is invalid, without jurisdiction, bad in law and must be deleted. He relied on the following case law: 1. Heval Navinbhai Patel