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

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

b) Six months from the end of the month in which the action for imposition of penalty is initiated, whichever is later. In the present case, the assessment under section 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

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

penalty u/s 271(1)(b), the learned DR submitted that it is a clear case of non- compliance of the statutory notices issued u/s 142(1) of the Act and for this failure, the provisions of section

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

penalty u/s 271(1)(b), the learned DR submitted that it is a clear case of non- compliance of the statutory notices issued u/s 142(1) of the Act and for this failure, the provisions of section

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

penalty u/s 271(1)(b), the learned DR submitted that it is a clear case of non- compliance of the statutory notices issued u/s 142(1) of the Act and for this failure, the provisions of section

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

b) has failed to comply with a notice under sub-section (2) of section 115WD or under sub-section (2) of section 115WE or under sub-section (1) of section 142 or sub-section (2) of section 143 or fails to comply with a direction issued under sub-section (2A) of section 142, or (c) has concealed the particulars

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

b) has failed to comply with a notice under sub-section (2) of section 115WD or under sub-section (2) of section 115WE or under sub-section (1) of section 142 or sub-section (2) of section 143 or fails to comply with a direction issued under sub-section (2A) of section 142, or (c) has concealed the particulars

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.

u/s. 274 of the Act should specifically state the grounds mentioned in section 271(1)(c) of the I.T.Act i.e whether it is for concealment of income or for furnishing of inaccurate particulars of income. The ld.counsel for the assessee drew the attention of the Bench to the various parameters laid down by the Hon’ble High Court

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.

u/s. 274 of the Act should specifically state the grounds mentioned in section 271(1)(c) of the I.T.Act i.e whether it is for concealment of income or for furnishing of inaccurate particulars of income. The ld.counsel for the assessee drew the attention of the Bench to the various parameters laid down by the Hon’ble High Court

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

u/s. 271(1)(c) and the penalty notices subsequently issued did not specify which limb the penalty proceedings had been initiated. The appellant in his support quoted a few case laws regarding the penalty notices and recording of satisfaction in assessment order. It is observed from the assessment order that the AO has mentioned penalty proceedings are initiated

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.

b) of section 275(1)(c) of the Act provides Six months from the end of the month in which the action for initiation of penalty is initiated and in the present case the A.O has sent a proposal or reference to the Jt.CIT for taking necessary action on 25/05/2023. As held by the Hon'ble Karnataka High Court

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.

b) of section 275(1)(c) of the Act provides Six months from the end of the month in which the action for initiation of penalty is initiated and in the present case the A.O has sent a proposal or reference to the Jt.CIT for taking necessary action on 25/05/2023. As held by the Hon'ble Karnataka High Court

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

271(1)(c) of the Act. Ld.AR further contended that penalty proceedings are different from assessment proceedings and the assessee can always make fresh arguments for cancellation of penalty. 6. Per contra, ld.DR has drawn our attention to the order passed by ld.CIT(A) wherein it was held as under : 5.2. The only ground that requires to be adjudicated

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

271(1)(c) of the Act. Ld.AR further contended that penalty proceedings are different from assessment proceedings and the assessee can always make fresh arguments for cancellation of penalty. 6. Per contra, ld.DR has drawn our attention to the order passed by ld.CIT(A) wherein it was held as under : 5.2. The only ground that requires to be adjudicated

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

b) of section 275(1)(c) of the Act\nprovides Six months from the end of the month in which the\naction for initiation of penalty is initiated and in the present case\nthe A.O has sent a proposal or reference to the Jt.CIT for taking\nnecessary action on 25/05/2023. As held by the Hon'ble\nKarnataka High Court

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

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

b) of section 275(1)(c) of the Act\nprovides Six months from the end of the month in which the\naction for initiation of penalty is initiated and in the present case\nthe A.O has sent a proposal or reference to the Jt.CIT for taking\nnecessary action on 25/05/2023. As held by the Hon'ble\nKarnataka High Court

MOHHAMAD WAJAHAT ALI KHAN ,HYDERABAD vs. INCOME TAX OFFICER (INT TAXN)-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 No. 848/Hyd/2024 (िनधा"रण वष"/Assessment Year: 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 Srinath Sadanala, Dr सुनवाई की तारीख/Date Of Hearing: 28/10/2024 घोषणा की तारीख/Pronouncement: 28/10/2024 आदेश/Order

section 272A(1)(d) of the Act and levied penalty for non-furnishing of return of income. As regards the levy of penalty u/s 271(1)(b

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

In the result, the appeal filed by the assessee is\nOrder pronounced in the Open Court on 6th February, 2026

u/s 271(1)(c) of the\nAct initiated separately.” However, there is no recording of\nsatisfaction whatsoever by the Ld. AO as to the specific charge,\nnamely, whether the penalty proceedings were initiated for\nconcealment of particulars of income or for furnishing of\ninaccurate particulars of income. It is well settled that recording of\nclear and unambiguous satisfaction

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

1)] Notwithstanding anything contained in section 139, section 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