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

In the result, three appeals i

section 269SS\nof the Act, in the assessment order passed u/s 143(3) rws 153A of\nthe Act dated 30.12.2019.\n6.\nThe Ld. CIT(A) failed to consider that the AO has not recorded\nsatisfaction for involving penal provisions u/s 271D of the Act and\nthus, the penalty order passed u/s 271D on 23.06.2021 is invalid\nand

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

penalty proceedings after the period of limitation.", "result": "Allowed", "sections": [ "Sec. 143(1)", "Sec. 271D", "Sec. 154", "Sec. 250", "Sec. 11", "Sec. 12", "Sec. 10B", "Sec. 119(2)(b)", "Sec. 269SS", "Sec. 273B", "Sec. 68

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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.

section 65B of the Indian Evidence Act, held as follows: “6. We have heard the rival contentions made by both the parties and gone through the orders of the authorities below. There is no dispute on the fact that the Revenue authorities have not filed the certificate u/s 65B of the Indian Evidence Act. However as per the decision

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 :

penalty under Section 271D. ITA Nos.575 to 578/Hyd/2025 4 8. That the learned CIT(A) has erred in not appreciating that the assessment was completed ex-parte under Section 144 r.w.s. 153A of the Act, thereby denying the appellant a reasonable opportunity to substantiate the sources of the alleged cash loans, which resulted in an arbitrary addition under Section 68

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 :

penalty under Section 271D. ITA Nos.575 to 578/Hyd/2025 4 8. That the learned CIT(A) has erred in not appreciating that the assessment was completed ex-parte under Section 144 r.w.s. 153A of the Act, thereby denying the appellant a reasonable opportunity to substantiate the sources of the alleged cash loans, which resulted in an arbitrary addition under Section 68

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 :

penalty under Section 271D. ITA Nos.575 to 578/Hyd/2025 4 8. That the learned CIT(A) has erred in not appreciating that the assessment was completed ex-parte under Section 144 r.w.s. 153A of the Act, thereby denying the appellant a reasonable opportunity to substantiate the sources of the alleged cash loans, which resulted in an arbitrary addition under Section 68

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 :

penalty under Section 271D. ITA Nos.575 to 578/Hyd/2025 4 8. That the learned CIT(A) has erred in not appreciating that the assessment was completed ex-parte under Section 144 r.w.s. 153A of the Act, thereby denying the appellant a reasonable opportunity to substantiate the sources of the alleged cash loans, which resulted in an arbitrary addition under Section 68

KIRAN BALA GUPTA,HYDERABAD vs. ITO, WARD-10(1), HYDERABAD

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.341/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2012-13) Smt. Kiran Bala Gupta, Vs. Income Tax Officer, Hyderabad. Ward-10(1), Pan: Ahvpg6893K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Av Raghuram, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 20/12/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/08/2022 For The Assessment Year (Ay) 2012-13. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

section 68 of the Act. 21. Be that as it may, as we have quashed the penalty imposed by the AO with

VAISHNAVI BULLION PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68 and assessed-as such, @ 60% tax irate as prescribed under provisions of section 115BBE of the IT Act.” In view of the detailed discussion above and the provisions of section 270A(9), I am satisfied that the assessee has indulged in under-reporting of income in consequence of mis-reporting of income, and accordingly, Penalty

MUSADDILAL GEMS JEWELS PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68 and assessed-as such, @ 60% tax irate as prescribed under provisions of section 115BBE of the IT Act.” In view of the detailed discussion above and the provisions of section 270A(9), I am satisfied that the assessee has indulged in under-reporting of income in consequence of mis-reporting of income, and accordingly, Penalty

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. VAISHNAVI BULLION PRIVATE LIMITED, HYDERABAD

In the result, we uphold the addition of Rs

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

68 and assessed-as such, @ 60% tax irate as prescribed under provisions of section 115BBE of the IT Act.” In view of the detailed discussion above and the provisions of section 270A(9), I am satisfied that the assessee has indulged in under-reporting of income in consequence of mis-reporting of income, and accordingly, Penalty