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Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM
Before: SHRI DUVVURU RL REDDY, HON’BLE & SHRI S BALAKRISHNAN, HON’BLE
of 20% in order to have substantial interest in a company. The ground raised by Revenue on Explanation 3(b) to section 2(22)(e) refers to a concern other than a company and hence not relevant for the instant case. We therefore find that there is no requirement to interfere in the order of the Ld. CIT(A) on this ground. Accordingly the appeal of the Revenue on this ground is dismissed.
Ground No.2 with respect to legal issue raised by the Revenue, since the appeal is adjudicated on merits against the Revenue, this legal issue need not be adjudicated.
Ground Nos. 1 & 4 are general in nature and needs no adjudication.
In the result, appeal of the Revenue is dismissed.
7 10. Cross Objection raised by the assessee is supportive in nature and therefore the adjudication of the CO becomes infructuous. Pronounced in the open Court on the 29th March, 2023.
Sd/- Sd/- (दु�वू� आर.एल रे�डी) (एस बालाकृ�णन) (DUVVURU RL REDDY) (S.BALAKRISHNAN) �या�यकसद�य/JUDICIAL MEMBER लेखा सद�य/ACCOUNTANT MEMBER Dated : 29.03.2023 OKK - SPS आदेश क� ��त�ल�प अ�े�षत/Copy of the order forwarded to:- �नधा�रती/ The Assessee – M/s. Vijaynagar Food and Nutraceuticals 1. Private Limited, 9-29-15/7, 3rd Floor, Padmavathi Towers, Balaji Nagar, Upstairs Canara Bank Regional Office, VIP Road, Siripuram, Visakhapatnam, Andhra Pradesh – 530003. राज�व/The Revenue – Assistant Commissioner of Income Tax, Central 2. Circle-1, 5th Floor, Direct Taxes Building, Sector-8, MVP Double Road, Visakhapatnam, Andhra Pradesh-530017.
The Principal Commissioner of Income Tax, आयकर आयु�त (अपील)/ The Commissioner of Income Tax (Appeals)-3, 4. Visakhapatnam. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, �वशाखापटणम/ 5. DR, ITAT, Visakhapatnam गाड� फ़ाईल / Guard file 6. आदेशानुसार / BY ORDER
Sr. Private Secretary ITAT, Visakhapatnam