आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G. ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.972 & 973/Hyd/2024 Assessment Years 2019-2020 & 2020-2021 And आ.अपी.सं /ITA.Nos.1300 & 1301/Hyd./2025 Assessment Years 2017-2018 and 2020-2021 Ravi Rishi Educational The DCIT, Society, Hyderabad. Central Circle-2(4), vs.

PAN AAAAR1952M Hyderabad. Telangana. Telangana.

(Appellant) (Respondent)

िनधा१ौरती (cid:554)ारा /Assessee by: CA P Murali Mohan Rao राज(cid:830) व (cid:554)ारा /Revenue by: Dr. Narendra Kumar Naik, CIT-DR सुनवाई की तारीख/Date of hearing: 20.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/ORDER PER VIJAY PAL RAO, VICE PRESIDENT :

These four appeals by the Assessee are directed against the four separate Orders of the learned CIT(A). The appeals in ITA Nos.972 and 973/Hyd/2024 are directed against the two separate Orders both dated 27.08.2024 of the learned CIT(A)-12, Hyderabad arising from the processing of the return of income u/sec.143(1) of the Income Tax Act [in short "the Act"], 1961 for the assessment years 2019-2020 and 2020-2021, respectively. The appeals ITA.No.1300/Hyd./2025 is directed against the Order dated 07.07.2025 of the learned CIT(A)-12, Hyderabad arising from penalty levied u/sec.271D of the Act for the assessment year 2017-2018. The appeal ITA.No.1301/ Hyd./ 2025 is directed against the Order dated 10.07.2025 of the learned CIT(A) arsing from the Order passed u/sec.154 of the Act for the assessment year 2020-2021.

2. In the quantum appeals for the assessment years 2019-2020 and 2020-2021 the assessee has raised common grounds. The grounds raised for the assessment year 2019-2020 in ITA.No.972/Hyd./2024 are reproduced as under: “The order passed u/s 250 of the Act dated 27.08.2024 is

1. erroneous both on facts and in law to the extent the order is prejudicial to the interests of the appellant.

2. The Ld. CIT(A) erred in dismissing the appeal.

The Ld. CIT(A) has erred in holding that he is of the

3. considered opinion that the assessee is not prevented from reasonable cause for filing Form 10B within the prescribed time limit.

The Ld. CIT(A) has erred in holding that since the

3.1.

application for condonation of delay in filing Form 10B has been rejected by the DGIT(Inv), Hyderabad, the entire gross receipts of Rs.10,76,34,264/- are to be treated as income of the appellant for the AY 2019-20.

The Ld. CIT(A) erred in observing that the natural consequence of rejection by the DGIT (Inv), Hyderabad, of

3.2. condonation of delay in filing Form 10B is loss of Tax Exemption to the appellant and that the appellant-trust becomes liable to pay income tax on its earnings.

The Ld. CIT(A) ought to have appreciated that when there

3.3. is a valid registration granted to the assessee-trust, making it liable to pay income tax on its earnings is not justified.

The Ld. CIT(A) ought to have fairly appreciated that the

3.4. delay upto 3 years period in filing Form-10B can be condoned by the Authority of Revenue.

The Ld. CIT(A) ought to have appreciated the fact that the

3.5. delay in filing of Audit Report in Form No. 10B is due to the search operation conducted which delayed the finalisation of books of accounts and the further delay is due to COVID-

19 pandemic and post COVID effects.

The Ld. CIT(A) erred in dismissing the appeal without appreciating the fact that the genuine claim of exemption

3.6. cannot be disallowed on a technical reason of delay in filing of the Audit Report in Form No. 10B, which is due to a reasonable cause and the same is beyond the control of the appellant.

The Ld. CIT(A) has erred in observing that the appellant

4. has not given any reasonable cause for delay in filing the appeal by over 188 days and that therefore the delay is not condoned leading to the dismissal of the appeal in limine.

The Ld. CIT(A) ought to have appreciated the fact that the delay in filing of the appeal is due to