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.

4. Subsequently, the AO initiated penalty proceedings u/s. 271(1)(c) of the I.T.Act and asked the assessee to explain as to why penalty should not be levied u/s. 271(1)(c) of the I.T.Act submitted that he has neither concealed the income nor submitted inaccurate particulars of income since the assessee section

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

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

4), Hyderabad in ITA. Nos.591/Hyd/2022 and others. 14. The Ld. CIT-DR, Ms. U. Mini Chandran, supporting the order of the Ld. CIT (A) submitted that, there is no merit in the legal ground taken by the assessee challenging the limitation in passing the penalty order under section 271D of the Act, because as per the provisions of section

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

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

4), Hyderabad in ITA. Nos.591/Hyd/2022 and others. 14. The Ld. CIT-DR, Ms. U. Mini Chandran, supporting the order of the Ld. CIT (A) submitted that, there is no merit in the legal ground taken by the assessee challenging the limitation in passing the penalty order under section 271D of the Act, because as per the provisions of section

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

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

4), Hyderabad in ITA. Nos.591/Hyd/2022 and others. 14. The Ld. CIT-DR, Ms. U. Mini Chandran, supporting the order of the Ld. CIT (A) submitted that, there is no merit in the legal ground taken by the assessee challenging the limitation in passing the penalty order under section 271D of the Act, because as per the provisions of section

CMR ENGINEERING EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel

NETENRICH TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: SHRI MANJUNATHA G. (Accountant Member), SHRI K.NARASIMHA CHARY (Judicial Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has outside the institution premises. Further, Shri Marri Rajashekhar Reddy had also quantified the amount attributable

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has outside the institution premises. Further, Shri Marri Rajashekhar Reddy had also quantified the amount attributable

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel fee and also quantified the amount of hostel fee collected from

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel fee and also quantified the amount of hostel fee collected from

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel fee and also quantified the amount of hostel fee collected from

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel fee and also quantified the amount of hostel fee collected from

MARRI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has outside the institution premises. Further, Shri Marri Rajashekhar Reddy had also quantified the amount attributable

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

u/s 132(4) of the Act on the date of search, and explained that the package amount received from the students includes tuition fee for all four academic years, miscellaneous fee, and hostel fee. Further, the managing trustee or member, Shri Marri Rajashekhar Reddy, has clearly bifurcated the amount attributable to tuition fee and the amount attributable to hostel

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.

u/s 271D of the Act. The Penalty Order was made on 22.02.2018. If the reckoning point is 16.11.2016, it is clear that the proceedings were completed beyond the period of limitation, as rightly contended by the learned counsel appearing for the Assessee. Even otherwise , the concept of delay & latches would crop in; no explanation whatsoever has been offered

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.

u/s 271D of the Act. The Penalty Order was made on 22.02.2018. If the reckoning point is 16.11.2016, it is clear that the proceedings were completed beyond the period of limitation, as rightly contended by the learned counsel appearing for the Assessee. Even otherwise , the concept of delay & latches would crop in; no explanation whatsoever has been offered