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

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

275(1)(c) of the Act and after considering the relevant facts has held as under: “6.7 In the facts of this case, these twin purposes can be achieved by treating the reference by the ITO to the Additional Commissioner as the triggering point or initiation of penalty proceedings. The ITO vide letter dated 16.11.2016 had admittedly made the reference

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.

275 (1)(c) of the Act and after considering the relevant facts has held as under: “6.7 In the facts of this case, these twin purposes can be achieved by treating the reference by the ITO to the Additional Commissioner as the triggering point or initiation of penalty proceedings. The ITO vide letter dated 16.11.2016 had admittedly made the reference

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.

275 (1)(c) of the Act and after considering the relevant facts has held as under: “6.7 In the facts of this case, these twin purposes can be achieved by treating the reference by the ITO to the Additional Commissioner as the triggering point or initiation of penalty proceedings. The ITO vide letter dated 16.11.2016 had admittedly made the reference

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

275 (1)(c) of the Act and after considering the relevant facts has held as under: “6.7 In the facts of this case, these twin purposes can be achieved by treating the reference by the ITO to the Additional Commissioner as the triggering point or initiation of penalty proceedings. The ITO vide letter dated 16.11.2016 had admittedly made the reference

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

penalty proceedings under section 271 (1)(c) of the Act which got barred by limitation under section 275(1) of the Act.” 3. Similar grounds were raised by the assessee in other appeal also i.e., ITA 231/Hyd/2023 for A.Y. 2017-18 except the amounts involved. 4. Before us, both the parties submitted that the issues raised in both the appeals

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

penalty proceedings under section 271 (1)(c) of the Act which got barred by limitation under section 275(1) of the Act.” 3. Similar grounds were raised by the assessee in other appeal also i.e., ITA 231/Hyd/2023 for A.Y. 2017-18 except the amounts involved. 4. Before us, both the parties submitted that the issues raised in both the appeals

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

275 (1)(c) of the Act and after considering the relevant facts has held as under: “6.7 In the facts of this case, these twin purposes can be achieved by treating the reference by the ITO to the Additional Commissioner as the triggering point or initiation of penalty proceedings. The ITO vide letter dated 16.11.2016 had admittedly made the reference

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

u/s 274 r.w.s. 271AAB of the Act had observed that ; "It is clear from the Sub Section (3) of Section 271 AAB that Sections 274 and Section 275 of the Act shall, so far as may be, apply. Sub Section (1) of Section 274 of the Act mandates that order imposing penalty

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

u/s 274 r.w.s. 271AAB of the Act had observed that ; "It is clear from the Sub Section (3) of Section 271 AAB that Sections 274 and Section 275 of the Act shall, so far as may be, apply. Sub Section (1) of Section 274 of the Act mandates that order imposing penalty

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

u/s. 275(1)(c) on 13.03.2000 is according to period of limitation prescribed by either limbs of the clause (c) of 275(1). It was held that in case of penalty under section 271

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

u/s. 275(1)(c) on 13.03.2000 is according to period of limitation prescribed by either limbs of the clause (c) of 275(1). It was held that in case of penalty under section 271

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

u/s. 275(1)(c) on 13.03.2000 is according to period of limitation prescribed by either limbs of the clause (c) of 275(1). It was held that in case of penalty under section 271

AMD RESEARCH & DEVELOPMENT CENTER INDIA PRIVATE LIMITED(NOW KNOWN AS AMD INDIA PRIVATE LIMITED),BANGALORE vs. JT. COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), HYDERABAD

Appeals are allowed in above terms

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

u/s. 275(1)(c) on 13.03.2000 is according to period of limitation prescribed by either limbs of the clause (c) of 275(1). It was held that in case of penalty under section 271

BALREDDY GADE,SECUNDERABAD vs. ADDL. CIT., CENTRAL RANGE-1, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

271(1)(c) of the Act. c. Hold that the transactions recorded in the memorandum books, being derived from the seized and impounded materials, constitute admissible evidence and must be treated as a whole, rather than being selectively applied for penal consequences. d. Grant such other relief as may be deemed just and proper in the facts and circumstances

BALREDDY GADE,SECUNDERABAD vs. ADDL. CIT., CENTRAL RANGE-1, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

271(1)(c) of the Act. c. Hold that the transactions recorded in the memorandum books, being derived from the seized and impounded materials, constitute admissible evidence and must be treated as a whole, rather than being selectively applied for penal consequences. d. Grant such other relief as may be deemed just and proper in the facts and circumstances

BALREDDY GADE,SECUNDERABAD vs. ADDL. CIT., CENTRAL RANGE-1, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

271(1)(c) of the Act. c. Hold that the transactions recorded in the memorandum books, being derived from the seized and impounded materials, constitute admissible evidence and must be treated as a whole, rather than being selectively applied for penal consequences. d. Grant such other relief as may be deemed just and proper in the facts and circumstances

BALREDDY GADE,SECUNDERABAD vs. ADDL. CIT., CENTRAL RANGE-1, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

271(1)(c) of the Act. c. Hold that the transactions recorded in the memorandum books, being derived from the seized and impounded materials, constitute admissible evidence and must be treated as a whole, rather than being selectively applied for penal consequences. d. Grant such other relief as may be deemed just and proper in the facts and circumstances

DAWAT E ISLAMI AP,HYDERABAD vs. ITO., EXEMPTION WARD 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1575/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2015-16) Dawat E Islami Ap, Vs. Income Tax Officer, Hyderabad. Exemption Ward-1(1), Pan: Aabtd5383Q Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Ankit Chokshi, Ca (Hybrid Mode) Assessee Represented By राज"वका""त"न"ध"व/ : Shri Mathivanan S A, Sr. Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 05/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 11/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Dawat E Islami Ap, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 25/07/2025 For The A.Y.2015-16. Dawat E Islami Ap Vs. Ito

section 271(1)(c) of the Act, i.e. concealment of particulars of income or furnishing of inaccurate particulars of income, the penalty was triggered and Initiated. Ld. CIT(A) erred in law in law in not allowing the said ground of appeal. 2. The satisfaction drawn by the Ld. AO while initiating proceeding u/s 271(1