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2026 Supreme(Online)(ITAT) 7821

INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
G. Manjunatha, Accountant Member, Ravish Sood, Judicial Member
Aurora Educational Society – Appellant
Versus
Assistant Commissioner of Income-tax, Central Circle – 2(4), Hyderabad – Respondent


Advocates:
For the Appellants/Petitioners: Shri P. Murali Mohan Rao, C.A.
For the Respondents: Ms. U. Mini Chandran, CIT-DR

Table of Content
1. consolidated appeals against penalty orders (Para 1 , 2)
2. search, assessment, and penalty initiation history (Para 3 , 4 , 5 , 6)
3. penalty proceedings and cit(a) upholding (Para 7 , 8 , 9 , 10 , 11)
4. parties' arguments on limitation and merits (Para 12 , 13 , 14 , 15)
5. limitation under section 275(1)(c) from ao reference (Para 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23)
6. no penalty for cash sale of agricultural land (Para 24 , 25 , 26 , 27 , 28 , 29)
7. appeals allowed for all assessment years (Para 30 , 31 , 32 , 33)

ORDER

PER MANJUNATHA G., A.M :

The appeals filed by the assessee are directed against the separate, but identical orders of the learned Commissioner of Income Tax (Appeals) – 12, Hyderabad (for short “Ld. CIT(A)”) all dated 01.07.2025, pertaining to the assessment years 2016-17 to 2018-19, respectively. Since common issues are involved in these appeals, the same were heard together and are being disposed off, by this single consolidated order for the sake of convenience and brevity.

2. First, we take up appeal in ITA No. 1255/Hyd/2025 for A.Y. 2016-17. The grounds raised by the assessee in this appeal are re- produced as under:

“1.The order of the Ld. CIT

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