MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL. CIT, CENTRAL RANGE-2, HYDERABAD
In the result, the appeals filed by the assessee for the A
ITA 2172/HYD/2025[2021-22]Status: DisposedITAT Hyderabad25 Feb 2026AY 2021-22
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.
For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 271DSection 274
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