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आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL

Hyderabad ‘A/B/SM‘ Bench, Hyderabad

(cid:373)ी रिवश सूद,(cid:586)ाियक सद(cid:735) एव ं(cid:373)ी मधुसूदन साविड़या लेखा सद(cid:735) सम(cid:407) |

Before Shri Ravish Sood, Judicial Member A N D

Shri Madhusudan Sawdia, Accountant Member

S.No Appeal in ITA Appellant RespondAepnpt eal Appealed No. & A.Y. against the

order & Date of

order

1 1208/Hyd/2026 Srimathi Income Tax Addl/JCIT(A)-5

2020-21 Chellaswamy, Officer, Ward Chennai, Hyderabad 13(1), Hyderabad 13/02/2026 PAN:ADKPC2519B

2 1209/Hyd/2026 -do- -do- -do-

2021-22

3 1224/Hyd/2026 Sharath Chander Income Tax Addl/JCIT(A)-2

2021-22 Loka, Siddipet Officer, Kolkata, PAN:ABOPL7774K Ward-1, Siddipet 13.02.2026

4 1530/Hyd/2026 Arun Kumar Income Tax Addl/JCIT(A)-2

2020-21 Battina, Officer, Ward- Kolkata, Hyderabad 13(1), Hyderabad 24.02.2026 PAN:AGOPB2913M

5 1531/Hyd/2026 -do- -do- -do-

2021-22

6 1989/Hyd/2026 Banapuram -do- Addl/JCIT(A)-4, 2020-21 Ramesh, Delhi, Hyderabad 28.04.2026

PAN:ACPPB6710M

7 1990/Hyd/2026 -do- -do- Addl/JCIT(A)-4, 2021-22 Delhi, 26.05.2026

8 2131/Hyd/2026 Juluru Brahma -do- Addl/JCIT(A)-2

2021-22 Chary, NAGPUR, Ranga Reddy 30.04.2026 PAN: ABFPJ6091A

9 1329/Hyd/2026 Rammohan Koppu Income Tax Addl/JCIT(A)-5, 2024-25 Hyderabad Officer, Delhi, PAN:AQLPK5583F Ward -1, 11.02.2026

WARANGAL

10 2084/Hyd/2026 Devendar Reddy Income Tax Addl/JCIT(A)-2

2020-21 Hyderabad Officer, Ward- Kolkata, PAN:ACBPR3850N 13(3), Hyderabad 05.03.2026

11 2085/Hyd/2026 -do- -do- -do-

2021-22

12 2174/Hyd/2026 Avadutha Ramesh Income Tax Addl/JCIT(A)-2

2020-21 Malkajgiri Officer, Ward-1 Kolkata PAN:AERPA7686K Sangareddy 08.05.2026

13 2175/Hyd/2026 -do- -do- -do-

2021-22

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आदेश/ORDER Per Bench :

These 13 appeals filed by different assessees are directed against the separate orders passed by the Learned Addl/JCIT(A) relating to the assessment years 2020-21, 2021- 22 & 2024-25, the details whereof are given in the cause title. Since identical facts and common issues are involved in all these appeals, they were heard together and are being disposed

of by this consolidated order for the sake of convenience.

2. For the sake of brevity, the grounds raised by the assessee in ITA No.1208/Hyd/2026 for A.Y. 2020-21 are only

reproduced as under:

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3. The common facts emerging from all the appeals are that the assessees were employees of Bharat Sanchar Nigam Limited (“BSNL”), a Public Sector Undertaking under the administrative control of the Department of Telecommunications, Government of India. Pursuant to the decision of the Union Cabinet for revival of BSNL by, inter alia, reducing employee costs, administrative allotment of spectrum

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for 4G services and other restructuring measures, BSNL introduced the Voluntary Retirement Scheme, 2019 (“VRS- 2019”) for its employees aged 50 years and above by offering ex-gratia compensation. The assessees in the present batch of appeals opted for the said VRS-2019 and received ex-gratia compensation from BSNL during the relevant previous years corresponding to the assessment years under consideration. While making the payment, BSNL deducted tax at source. The assessees, while filing their returns of income for the respective assessment years, offered the ex-gratia compensation to tax after claiming exemption of ₹5,00,000/- under section 10(10C) of the Income-tax Act, 1961 (“the Act”). Consequently, the amount received in excess of ₹5,00,000/- was offered to tax. The returns of income of the assessee were processed by the Department under section 143(1) of the Act accepting the

returned income without raising any demand.

4. Subsequently, the assessees came to know that the ex-gratia compensation received under BSNL VRS-2019 was fully exempt under section 10(10B) of the Act. Accordingly, they preferred appeals before the Learned Addl/JCIT(A) against the intimations issued under section 143(1) of the Act. However, there was a substantial delay ranging from about 503 days

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