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

u/s 271D of the Act without any assessment\nproceedings in the case of the assessee is not valid and liable to be\nquashed. We order accordingly.\"\n7.\nThus, it is a pre-requisite condition for initiation of the\npenalty u/sec.271D/271E of the Act that there must be an assessment\nproceeding or proceedings arising from assessment order or any other\nproceedings

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

u/s 271D of the Act without any assessment\nproceedings in the case of the assessee is not valid and liable to be\nquashed. We order accordingly.\"\n7. Thus, it is a pre-requisite condition for initiation of the\npenalty u/sec.271D/271E of the Act that there must be an assessment\nproceeding or proceedings arising from assessment order or any other\nproceedings

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

u/s 271D of the Act without any assessment\nproceedings in the case of the assessee is not valid and liable to be\nquashed. We order accordingly.\n7.\nThus, it is a pre-requisite condition for initiation of the\npenalty u/sec.271D/271E of the Act that there must be an assessment\nproceeding or proceedings arising from assessment order or any other\nproceedings

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

D S R INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

D S R INFRASTRUCTUREPRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE- 1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

DCIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

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

SURESH KUMAR BACHIRAJU,KUKATPALLY vs. INCOME TAX OFFICER, WARD-11(1), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.177/Hyd/2024 (िनधा"रण वष" / Assessment Year: 2012-13) Shri Suresh Kumar Vs. Income Tax Officer Bachiraju, Ward 11(1) Kukatapally Hyderabad Pan:Afkpb6727Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Kiran Manohar राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 16/04/2024 घोषणा की तारीख/Pronouncement: 16/04/2024

penalty u/s 271(1)(c) of Rs.30,36,054/-. 6. The ld. CIT(A) ought to have considered the fact that the difference arose because of application of section

INCOME TAX OFFICER, WARD-1, CHITTOOR vs. G VIJAYASIMHA REDDY, BENGALURU

In the result, the appeal of Revenue in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

penalty proceedings u/s 271(1)C are being initiated.” 7.1. Before us, Ld. DR submitted that the activities of the assessee are in the nature of business as the assessee had entered into the JDA. The ld. DR submitted that the assessee had in fact had entered into JDA, which was akin to partnership, as there was an element

BHEL LCC SOCIETY LTD,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.732/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Bhel Lcc Society Ltd Vs. Dy.Cit Hyderabad Circle 8(1) Pan:Aaatb6430D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sri Sai Keerthana राज" व "ारा/Revenue By:: Shri Dr. Sachin Kumar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 01/09/2025 घोषणा की तारीख/Pronouncement: 04/09/2025 आदेश/Order Per Vijay Pal Raothis Appeal By The Assessee Is Directed Against The Order Dated 27/02/2025 Of The Learned Cit (A)-Nfac Delhi, Arising From The Penalty Order Passed U/S 270A Of The I.T. Act For The A.Y.2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

36(a)(va) of the I.T. Act towards belated payment of Employees Contribution to PF. Section 270A provides penalty for under reporting and misreporting of the income. For ready reference the said section 270A is quoted as under: Page 5 of 12 ITA No 732 of 2025 BHEL LCC SOCIETY

DAMODAR RAO BIBINAGAR,HYDERABAD vs. ITO., WARD-13(1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumarassessment Year: 2017-18 Damodar Rao Bibinagar, Vs. The Additional 1-8-74/6, Commissioner Of Income Chikkadapally, Tax, Hyderabad, Hyderabad. Telangana – 500020. Pan : Afjpb5620F. (Appellant) (Respondent) Assessee By: Sri A.V. Raghuram, Advocate. Revenue By: Ms. Harshita Chouhan, Sr.Ar Date Of Hearing: 26/12/2023 Date Of Pronouncement: 27/12/2023

penalty of Rs.13,10,000/- i.e., the sum equal to the amount of the cash of Rs.13,10,000/- received towards sale consideration, in accordance with the provisions of section 271 D of the Act. Thus, Assessing Officer passed order u/s 271D of the Act dt.28.09.2022. 4. Feeling aggrieved with the order of Assessing Officer passed u/s 271D

NIMMATOORI YASHODA,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

271, a proper satisfaction must be recorded to initiate penalty proceedings u/s 271D instead of a mere statement given by the AO in his order dated 21.12.2019. 9. a . The Ld. CIT(A) erred in dismissing ground nos. 11,12,13 & 15 taken before him. b. Without prejudice to other grounds, the Ld. CIT(A) ought to have appreciated that

NIMMATOORI SULOCHANA,HYDERABAD vs. ACIT., CENTRAL CIRCLE 2(4), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

271, a proper satisfaction must be recorded to initiate penalty proceedings u/s 271D instead of a mere statement given by the AO in his order dated 21.12.2019. 9. a . The Ld. CIT(A) erred in dismissing ground nos. 11,12,13 & 15 taken before him. b. Without prejudice to other grounds, the Ld. CIT(A) ought to have appreciated that

KERELE BALWANTH REDDY,RANGA REDDY vs. ITO., WARD-1, VIKARABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Along With An Affidavit & Explained The Reasons For Delay. Shri, S.K. Gupta, The Ld. Counsel For The Assessee Referring To The Petition Filed By The Assessee Submitted That, Although The Assessee Has Paid Appeal Fees On 5/10/2023 & Filed Relevant Form- 36 On 06/10/2023 But, Because Of Certain Errors In Digital Signature Certificate (In Short “Dsc”), The Form-36 Could Not Be Uploaded. However, The Assessee Has Obtained Dsc & Filed Digitally Signed Form- 36 On 10/01/2025 With A Delay Of 437 Days. The Said Delay Is Beyond The Control Of The Assessee. He Therefore Submitted That The Delay In Filing The Appeal Is Neither Intentional Nor For Want Of Any Undue Benefit. Therefore, In The Interest Of Justice, The Delay May Be Condoned.

36 on 06/10/2023 i.e., on or before the due date of filing the appeal before the Tribunal. The only reason for not filing the Form-36 with DSC is due to mistake in DSC which is beyond the control of the assessee. Therefore, we are of the view that the reasons given by the assessee for not filing the appeal

KERELE BALWANTH REDDY,RANGA REDDY vs. I.T.O., WARD-8(2), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Along With An Affidavit & Explained The Reasons For Delay. Shri, S.K. Gupta, The Ld. Counsel For The Assessee Referring To The Petition Filed By The Assessee Submitted That, Although The Assessee Has Paid Appeal Fees On 5/10/2023 & Filed Relevant Form- 36 On 06/10/2023 But, Because Of Certain Errors In Digital Signature Certificate (In Short “Dsc”), The Form-36 Could Not Be Uploaded. However, The Assessee Has Obtained Dsc & Filed Digitally Signed Form- 36 On 10/01/2025 With A Delay Of 437 Days. The Said Delay Is Beyond The Control Of The Assessee. He Therefore Submitted That The Delay In Filing The Appeal Is Neither Intentional Nor For Want Of Any Undue Benefit. Therefore, In The Interest Of Justice, The Delay May Be Condoned.

36 on 06/10/2023 i.e., on or before the due date of filing the appeal before the Tribunal. The only reason for not filing the Form-36 with DSC is due to mistake in DSC which is beyond the control of the assessee. Therefore, we are of the view that the reasons given by the assessee for not filing the appeal