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:

260A of the act which has also been admitted as substantial question of law, this itself shows that the issue is debatable and for this reason the penalty under section 271(1)(c) is not leviable. The same view was reiterated by the Hon'ble Delhi High Court in case of CIT Vs. Thomson Press India Ltd wherein

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

260A\nor an appeal to the Supreme Court under section 261 or revision\nunder section 263 or section 264 and an order imposing or enhancing\nor reducing or cancelling penalty or dropping the proceedings for the\nimposition of penalty is passed before the order of the Commissioner\n(Appeals) or the Appellate Tribunal or the High Court

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

68 & 69 of the Act were deleted by the Ld.\nCIT(A) and the Hon'ble ITAT, Hyderabad Vide its orders in Appeal\nno.10421/2019-20 dt. 21.04.2022 and ITA No. 146/Hyd/2022 dt.\n19.07.2022.\n9. The learned CIT(A) ought to have considered that several Judicial\nrulings and Circulars of the CBDT state that minor filing delays\nshould not deny tax exemptions

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

In the result, three appeals i

68 & 69 of the Act were deleted by the Ld.\nCIT(A) and the Hon'ble ITAT, Hyderabad Vide its orders in Appeal\nno.10421/2019-20 dt. 21.04.2022 and ITA No. 146/Hyd/2022 dt.\n19.07.2022.\n9.\nThe learned CIT(A) ought to have considered that several Judicial\nrulings and Circulars of the CBDT state that minor filing delays\nshould not deny tax exemptions

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

68 & 69 of the Act were deleted by the Ld.\nCIT(A) and the Hon'ble ITAT, Hyderabad Vide its orders in Appeal\nno.10421/2019-20 dt. 21.04.2022 and ITA No. 146/Hyd/2022 dt.\n19.07.2022.\n9. The learned CIT(A) ought to have considered that several Judicial\nrulings and Circulars of the CBDT state that minor filing delays\nshould not deny tax exemptions

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-3(2), HYDERABAD vs. P SHIVMOHAN REDDY, HYDERABAD

In the result, both the appeals filed by the Revenue are allowed for statistical purposes

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

260A of the Page 9 of 16 ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad 1961, the High Court, Income-tax Act, borrowing extensively from the orders of Commissioner (Appeals) and the Appellate Tribunal, held that no substantial question of law arose out of the order of the Appellate Tribunal. On appeal by Department before the Supreme Court: Held

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

ACIT, CENTRAL CIRCLE-2(2), HYDERABAD vs. CHINTHAKUNTA RAMESH SRIDEVI, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CC-1(3), HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

GVPR ENGINEERS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE1(3), HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD, HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

GVPR ENGINEERS LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1(3) , HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD, HYDERABAD vs. GVPR ENGINEERS LIMITED, HYDERABAD

In the result all the 5 appeals filed by the Revenue are dismissed and the 5 appeals filed by the assessee are partly allowed for statistical purposes

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

68,011 71,55,28,116 39,37,21,429 4,61,13,242 transmission line & sub station Total 21,16,60,32,546 2,70,24,57,035 3,40,25,84,925 1,49,82,77,354 1,40,42,35,024 46,86,52,111 15,40,23,546 17. He submitted that the learned

R A K CEREMICS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2014-15 R.A.K. Ceramics India Vs. The Deputy Commissioner Of Private Limited, Income Tax, P.O Box No.11, Circle 3(1), Adb Road, Samalkot, Hyderabad. Andhra Pradesh. Pin – 53340, Pan : Aaccr6424N. (Appellant) (Respondent) Assessee By: Shri Aliasagar Rampurwala, C.A. Revenue By: B. Balakrishna – Cit Dr Date Of Hearing: 01.05.2024 Date Of Pronouncement: 09.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2014-15 Arises From The Assessment Order Of The Deputy Commissioner Of Income Tax, Circle – 3(1), Hyderabad Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 254 Of The Income Tax Act Dated 28.11.2022. 2. The Grounds Raised By The Assessee Read As Under :

Sections 144C(13) and 254 of the Income Tax Act, 1961 ('the Act') to the extent prejudicial to the Appellant, is bad in law and is liable to be quashed. 2. On the facts and in the circumstances of the case and in law, Hon'ble Panel erred in upholding the action of the learned Transfer Pricing Officer

MADHUCON PROJECTS LIMITED, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

260A on the case on the order of the ITAT for the AYs 2007-08 and 2008-09. 4. The appellant craves leave to amend or alter any ground or add any other grounds which may be necessary.” 19. Ground No.1 is general in nature and does not require any specific adjudication. 20. Ground No.2 is regarding the addition

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), HYDERABAD vs. MADHUCON PROJECTS LIMITED, HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

260A on the case on the order of the ITAT for the AYs 2007-08 and 2008-09. 4. The appellant craves leave to amend or alter any ground or add any other grounds which may be necessary.” 19. Ground No.1 is general in nature and does not require any specific adjudication. 20. Ground No.2 is regarding the addition

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

260A on the case on the order of the ITAT for the AYs 2007-08 and 2008-09. 4. The appellant craves leave to amend or alter any ground or add any other grounds which may be necessary.” 19. Ground No.1 is general in nature and does not require any specific adjudication. 20. Ground No.2 is regarding the addition