AURORA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT., 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

275 (1)(c) of the Act and after considering the relevant\nfacts has held as under:\n“6.7 In the facts of this case, these twin purposes can be\nachieved by treating the reference by the ITO to the\nAdditional Commissioner as the triggering point or\ninitiation of penalty proceedings. The ITO vide letter dated\n16.11.2016 had admittedly made

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

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

275 (1)(c) of the Act and after considering the relevant\nfacts has held as under:\n“6.7 In the facts of this case, these twin purposes can be\nachieved by treating the reference by the ITO to the\nAdditional Commissioner as the triggering point or\ninitiation of penalty proceedings. The ITO vide letter dated\n16.11.2016 had admittedly made

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

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

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

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

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

275, presupposes the existence of\nassessment proceedings/revision proceedings or appeal proceedings arising\nfrom the assessment order or revision order and the limitation is provided\nas per outcome of these proceedings. In absence of assessment in the case of\nthe assessee the initiation of penalty is not valid and further when the\nsatisfaction for initiation of the penalty on the part

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

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

In the result, three appeals i

275, presupposes the existence of\nassessment proceedings/revision proceedings or appeal proceedings arising\nfrom the assessment order or revision order and the limitation is provided\nas per outcome of these proceedings. In absence of assessment in the case of\nthe assessee the initiation of penalty is not valid and further when the\nsatisfaction for initiation of the penalty on the part

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

275, presupposes the existence of\nassessment proceedings/revision proceedings or appeal proceedings arising\nfrom the assessment order or revision order and the limitation is provided\nas per outcome of these proceedings. In absence of assessment in the case of\nthe assessee the initiation of penalty is not valid and further when the\nsatisfaction for initiation of the penalty on the part

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

275, presupposes the existence of\nassessment proceedings/revision proceedings or appeal proceedings arising\nfrom the assessment order or revision order and the limitation is provided\nas per outcome of these proceedings. In absence of assessment in the case of\nthe assessee the initiation of penalty is not valid and further when the\nsatisfaction for initiation of the penalty on the part

KESIREDDY RAVINDER REDDY,HYDERABAD vs. ITO WARD-11(1), HYDERABAD

275,\npresupposes the existence of assessment proceedings/revision\nproceedings or appeal proceedings arising from the assessment order\nor revision order and the limitation is provided as per outcome of these\nproceedings. In absence of assessment in the case of the assessee\nthe initiation of penalty is not valid and further when the satisfaction\nfor initiation of the penalty on the part