THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

deemed dividend. 8. The Ld. AO also made addition of Rs. 12,68,449/- disallowing the interest paid to bank by holding that the advances taken by the assessee are not related to the business activity carried out by the assessee and therefore interest paid to 8 bank relatable to such interest free advances is not allowable

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 104, 105 & 106/Viz/2020 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2015-16) Dy. Commissioner Of Income Tax, Vs. M/S. Atr Ware Housing (P) Central Circle-2, Ltd., Visakhapatnam. Visakhapatnam. Pan: Aadca 2121 Q

TDS etc., and the assessee furnished the required details. 3. After verification of the books of accounts, the Ld. AO noted that during the year the assessee company availed certain loans from various parties during the year and the assessee was asked to explain the same along with proper documentary evidence. After considering the submissions of the assessee

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

deemed dividend. 8. The Ld. AO also made addition of Rs. 12,68,449/- disallowing the interest paid to bank by holding that the advances taken by the assessee are not related to the business activity carried out by the assessee and therefore interest paid to 8 bank relatable to such interest free advances is not allowable

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISAKHAPATNAM vs. ANUMOLU TIRUPATI RAYUDU(HUF),, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

deemed dividend. 8. The Ld. AO also made addition of Rs. 12,68,449/- disallowing the interest paid to bank by holding that the advances taken by the assessee are not related to the business activity carried out by the assessee and therefore interest paid to 8 bank relatable to such interest free advances is not allowable

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 104, 105 & 106/Viz/2020 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2015-16) Dy. Commissioner Of Income Tax, Vs. M/S. Atr Ware Housing (P) Central Circle-2, Ltd., Visakhapatnam. Visakhapatnam. Pan: Aadca 2121 Q

TDS etc., and the assessee furnished the required details. 3. After verification of the books of accounts, the Ld. AO noted that during the year the assessee company availed certain loans from various parties during the year and the assessee was asked to explain the same along with proper documentary evidence. After considering the submissions of the assessee

ATR WAREHOUSING PRIVATE LIMITED,VISAKHAPATNAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, , VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

TDS made details, bank account statements, copy of WT return filed etc., and the assessee’s Representative furnished the information called for. Thereafter, another notice U/s. 142(1) was issued called for further details like books of account, bills & Vouchers, details of share holders, breakup of certain items in the P & L Account, balance sheet, confirmation letters in respect

DCIT, CIRCLE - 3(1), VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

In the result, all the appeals filed by the revenue, viz

Bench: Shri Ravish Sood & Shri Balakrishnan S.

TDS certificates issued by the licensees/lessees indicated that the nature of payments made to the assessee company was towards “rent”. Accordingly, the AO held a conviction that, as the assessee company was not exploiting the subject properties for its commercial business activity, therefore, it could not be said that any business activity was the primary objective and letting

DCIT, CIRCLE -3(1), VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

In the result, all the appeals filed by the revenue, viz

Bench: Shri Ravish Sood & Shri Balakrishnan S.

TDS certificates issued by the licensees/lessees indicated that the nature of payments made to the assessee company was towards “rent”. Accordingly, the AO held a conviction that, as the assessee company was not exploiting the subject properties for its commercial business activity, therefore, it could not be said that any business activity was the primary objective and letting

DCIT, CIRCLE - 3(1), , VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

TDS certificates issued by the licensees/lessees indicated that the\nnature of payments made to the assessee company was towards “rent”.\nAccordingly, the AO held a conviction that, as the assessee company\nwas not exploiting the subject properties for its commercial business\nactivity, therefore, it could not be said that any business activity was the\nprimary objective and letting

GMEDAPADU PACS,GMEDAPADU vs. ITO, WARD-1, KAKINADA

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.574/Viz/2025 ("नधा"रण वष"/Assessment Year: 2020-21) G Medapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri Kss Sarma, Ca राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 16/10/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

deem it apposite to cull out the observations of the CIT(A), as under: 5.0 Findings and Decision: - 5.1 Ground 1: 1. The assessing officer has erred in treating the paddy procurement commission received by the assessee-society, as the income from non-members. Actually, the income of commission is from the services rendered to the members only. Appellant

THE POLEPALLI FARMERS SERVICE CO-OPERATIVE SOCIETY LTD,VIZIANAGARAM vs. INCOMETAX OFFICER, WARD-1, VIZIANAGARAM

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.95/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2017-18) The Polepalli Farmers Service Co- Vs. Income Tax Officer Operative Society Ltd., Ward-1 B1612, Polepalli Village Vizianagaram Vizianagaram [Pan : Aaeat0705C] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri M.N.Murthy Naik, Cit(Dr) सुनवधई की तधरीख / Date Of Hearing : 16.11.2022 घोर्णध की तधरीख/Date Of Pronouncement : 16.12.2022 O R D E R Per Shri Duvvuru Rl Reddy: This Appeal Is Filed By The Assessee Against The Order Of The Principal Commissioner Of Income Tax [In Short, [Pcit], Visakhapatnam-1 In Din & Order No.Itba/Rev/F/Rev5/2021-22/1040343411(1) Dated 04.03.2022 For The Assessment Year (A.Y.) 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Primary Farmers Service Co-Operative Society, Filed It’S Return Of Income In The Status Of Aop, For The A.Y.2017-18 On 31.03.2018, Declaring Nil Taxable Income, After Claiming Deduction Of Entire Income U/S 80P Of The Income Tax Act, 1961

TDS of Rs.1,08,312/- deducted by the State Bank of India, ADB, Visakhapatnam and the State Bank of India, Chittivalasa Branch, in which the assessee had invested in fixed deposits and earned interest income, as evident from the schedule of investments annexed to balance sheet as on 31.03.2017 during the previous year, relevant to the A.Y.2017-18. However, the Ld.PCIT