GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

TDS credit of Rs. 5,000/-). Against the aforesaid tax liability, the assessee had paid self-assessment tax of Rs. 84,676/- on 07/03/2020 and arrived at the balance tax liability of Rs. 2,89,080/-. Gattula Lakshmi Madhavi vs. ACIT 5. Thereafter, the assessee, in response to notice under section 148 of the Act, dated 30/03/2022, had filed

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

TDS credit of Rs. 5,000/-). Against the aforesaid tax liability, the assessee had paid self-assessment tax of Rs. 84,676/- on 07/03/2020 and arrived at the balance tax liability of Rs. 2,89,080/-. Gattula Lakshmi Madhavi vs. ACIT 5. Thereafter, the assessee, in response to notice under section 148 of the Act, dated 30/03/2022, had filed

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

TDS credit of Rs. 5,000/-). Against the aforesaid tax liability, the assessee had paid self-assessment tax of Rs. 84,676/- on 07/03/2020 and arrived at the balance tax liability of Rs. 2,89,080/-. Gattula Lakshmi Madhavi vs. ACIT 5. Thereafter, the assessee, in response to notice under section 148 of the Act, dated 30/03/2022, had filed

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. DODDI ROOPA, VISAKHAPATNAM

In the result, the appeal filed by the revenue is dismissed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.413/Viz/2024 (िनधा"रण वष"/Assessment Year: 2019-20) Deputy Commissioner Of Vs. Smt. Doddi Roopa, Income Tax, Visakhapatnam. Circle-3(1), Visakhapatnam. Pan: Atfpr7237N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement:

TDS) on the payments made to M/s. A.K. Capital Enterprises, as against the purchases made during the year under consideration. Accordingly, the AO, based on his conviction that 4 DCIT vs. Smt. Doddi Roopa the assessee has failed to justify the purchases of Rs. 4,99,65,247/-, passed an order under section 148A(d) of the Act, dated 29/03/2023

RANAR AGROCHEM LIMITED,PARAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

Section 2(24)(x) is found to be valid and proper in fact and law. Considering the totality of the facts and circumstances of the case, the disallowance of Rs. 2,32,202/- on the above account is confirmed and the ground no. 1 of the appellant is dismissed. 5.4 Ground No. 3 relates to addition

MARIAPPAN AUSTIN PRAKASH,BENGALURU, KANRNATAKA vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTL TXN CIRCLE, VISAKHAPATNAM

TDS amount of Rs.86,26,842/-. Thereafter, a\nquestionnaire under section 142(1) of the Act was issued and served on the\nassessee to provide the period of stay in India and the assessee in response\nsubmitted that he has stayed in India less than sixty (60) days during the\nimpugned assessment year and further submitted the Tax Residency Certificate

SRI LAKSHMI GENERAL STORES,GUNTUR vs. INCOME TAX OFFICER, WARD-1(1), GUNTUR

In the result, appeal of the assessee in ITA

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

1)(b) of the Andhra Pradesh Agricultural Produce and Livestock Market Act, 1966. As per AMC regulations, the assessee receives 2% commission from farmers on sales to purchasers/traders/ exporters, and the same has been offered as income in the financial statements and paid relevant taxes. The buyers/traders/exporters deducted TDS under Section 194Q in respect of sales on the total sale

SRI LAKSHMI GENERAL STORES,GUNTUR vs. INCOME TAX OFFICER, WARD-1(1), GUNTUR

In the result, appeal of the assessee in ITA

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

1)(b) of the Andhra Pradesh Agricultural Produce and Livestock Market Act, 1966. As per AMC regulations, the assessee receives 2% commission from farmers on sales to purchasers/traders/ exporters, and the same has been offered as income in the financial statements and paid relevant taxes. The buyers/traders/exporters deducted TDS under Section 194Q in respect of sales on the total sale

INDIRA VOONA,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-3(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A. No. 244/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2017-18) Indira Voona V. Income Tax Officer – Ward 3(1) Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A. No. 268/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2015-16) Income Tax Officer – Tds Ward -1 Indira Voona V. Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS Ward -1 Indira Voona v. Visakhapatnam Plot No. 24, Sector 12 MVP Colony, Visakhapatnam – 530017 Andhra Pradesh [PAN: AEWPV1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented by : Shri GVN Hari AR राजस्व का प्रतततितित्व/ Department Represented by : Dr. Aparna Villuri, Sr.AR सुिवाई समाप्त होिे की ततति/ Date of Conclusion of Hearing : 09.09.2024 घोर्णध की तधरीख/Date

INDIRA VOONA,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, TDS WARD 1, , VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A. No. 244/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2017-18) Indira Voona V. Income Tax Officer – Ward 3(1) Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A. No. 268/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2015-16) Income Tax Officer – Tds Ward -1 Indira Voona V. Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS Ward -1 Indira Voona v. Visakhapatnam Plot No. 24, Sector 12 MVP Colony, Visakhapatnam – 530017 Andhra Pradesh [PAN: AEWPV1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented by : Shri GVN Hari AR राजस्व का प्रतततितित्व/ Department Represented by : Dr. Aparna Villuri, Sr.AR सुिवाई समाप्त होिे की ततति/ Date of Conclusion of Hearing : 09.09.2024 घोर्णध की तधरीख/Date

INCOMETAX OFFICER, WARD-3(1), VISAKHAPATNAM vs. SURENDRA NATH GUBBALA, VISAKHAPATNAM

Bench: Us:

1). In other words, if, without removing any encumbrance, sale or transfer could not be affected, the amount paid for removing that encumbrance will fall under clause (i) of Section 48 of the Act. 35. We thus, in terms of our aforesaid deliberations, read in light of the settled position of law, are unable to concur with

ARABOLU VENKATA NAGA DEEPATHI REPRESENTED BY POWER OF ATTORNEY HOLDER, N. SATYARAMANUJAMM ,VISAKHAPATNAM vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), VISAKHAPATNAM

In the result, the appeal fails and the same is hereby dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.178/Viz/2018 (ननधधारण वर्ा/ Assessment Year : 2010-11) Smt.Arabolu Venkata Naga Deepthi Vs. Income Tax Officer Rep. By Power Of Attorney Holder (International Taxation) Smt. N.Satyaramanujam Visakhapatnam Flat No.403, Dhanna Apartments Seethammadhara Visakhapatnam [Pan : Atcpa6413A] (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

1)/(1A) was passed in the case of Sri T.Janardhana Rao on 12.02.2013 for not making TDS u/s 195 of the Income Tax Act, 1961 (in short ‘Act’) on the payments made by him to the assessee. Subsequently, the assessee filed her income tax return for the A.Y.2010-11 on 17.05.2013 admitting sale consideration of Rs.39,69,000/-, towards her share

BALAJEE CONSTRUCTIONS,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, TDS WARD-1, VISAKHAPATNAM

In the result, appeal filed by the assessee in ITA

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

TDS), Ward-1, Visakhapatnam. As per Form 35 column-2(c), it has been received on 10/05/2019 and appeal has been filed. It should be carefully noted that cause for grievance arose when order U/s. 200A/234E was passed which is appealable. Consequently, grounds of appeals being agitated, are primarily directed against order passed U/s. 200A/234E wherein penalty / late filing fees

BALAJEE CONSTRUCTIONS,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, TDS WARD-1, VISAKHAPATNAM

In the result, appeal filed by the assessee in ITA

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

TDS), Ward-1, Visakhapatnam. As per Form 35 column-2(c), it has been received on 10/05/2019 and appeal has been filed. It should be carefully noted that cause for grievance arose when order U/s. 200A/234E was passed which is appealable. Consequently, grounds of appeals being agitated, are primarily directed against order passed U/s. 200A/234E wherein penalty / late filing fees

BALAJEE CONSTRUCTIONS,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, TDS WARD-1, VISAKHAPATNAM

In the result, appeal filed by the assessee in ITA

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

TDS), Ward-1, Visakhapatnam. As per Form 35 column-2(c), it has been received on 10/05/2019 and appeal has been filed. It should be carefully noted that cause for grievance arose when order U/s. 200A/234E was passed which is appealable. Consequently, grounds of appeals being agitated, are primarily directed against order passed U/s. 200A/234E wherein penalty / late filing fees

VISAKHAPATNAM INDUSTRIAL WATER SUPPLY COMPANY LTD,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

In the result, appeals of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.Nos.137, 138 & 139/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2005-06, 2006-07 & 2007-08) Visakhapatnam Industrial Water V. Asst. Commissioner Of Income-Tax Circle – 4(1) Supply Company Limited Income Tax Office C/O. Gvmc, Room No. 204 Pratyakshakar Bhavan Teneti Bhavan, Asilmetta Junction Mvp Double Road Visakhapatnam – 530002 Visakhapatnam – 530017 Andhra Pradesh Andhra Pradesh [Pan:Aabcv2240H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No. 229/Viz/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) Visakhapatnam Industrial Water V. Dy. Commissioner Of Income-Tax Circle – 5(1) Supply Company Limited Income Tax Office C/O. Gvmc, Room No. 204 Pratyakshakar Bhavan Teneti Bhavan, Asilmetta Junction Mvp Double Road Visakhapatnam – 530002 Visakhapatnam – 530017 Andhra Pradesh Andhra Pradesh [Pan:Aabcv2240H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS compliance for certain expenses and scope of disallowance under section 43B for interest payments. Assessing Officer passed another assessment order allowing the same loss as in the earlier assessment order. Once again Ld. CIT – 2, Visakhapatnam on 28.03.2014 holding the order of the Assessing Officer as erroneous and prejudicial to the interest of the revenue passed an order under

VISAKHAPATNAM INDUSTRIAL WATER SUPPLY COMPANY LTD,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), VISAKHAPATNAM

In the result, appeals of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.Nos.137, 138 & 139/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2005-06, 2006-07 & 2007-08) Visakhapatnam Industrial Water V. Asst. Commissioner Of Income-Tax Circle – 4(1) Supply Company Limited Income Tax Office C/O. Gvmc, Room No. 204 Pratyakshakar Bhavan Teneti Bhavan, Asilmetta Junction Mvp Double Road Visakhapatnam – 530002 Visakhapatnam – 530017 Andhra Pradesh Andhra Pradesh [Pan:Aabcv2240H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No. 229/Viz/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) Visakhapatnam Industrial Water V. Dy. Commissioner Of Income-Tax Circle – 5(1) Supply Company Limited Income Tax Office C/O. Gvmc, Room No. 204 Pratyakshakar Bhavan Teneti Bhavan, Asilmetta Junction Mvp Double Road Visakhapatnam – 530002 Visakhapatnam – 530017 Andhra Pradesh Andhra Pradesh [Pan:Aabcv2240H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS compliance for certain expenses and scope of disallowance under section 43B for interest payments. Assessing Officer passed another assessment order allowing the same loss as in the earlier assessment order. Once again Ld. CIT – 2, Visakhapatnam on 28.03.2014 holding the order of the Assessing Officer as erroneous and prejudicial to the interest of the revenue passed an order under

VISAKHAPATNAM INDUSTRIAL WATER SUPPLY COMPANY LTD,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), VISAKHAPATNAM

In the result, appeals of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.Nos.137, 138 & 139/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2005-06, 2006-07 & 2007-08) Visakhapatnam Industrial Water V. Asst. Commissioner Of Income-Tax Circle – 4(1) Supply Company Limited Income Tax Office C/O. Gvmc, Room No. 204 Pratyakshakar Bhavan Teneti Bhavan, Asilmetta Junction Mvp Double Road Visakhapatnam – 530002 Visakhapatnam – 530017 Andhra Pradesh Andhra Pradesh [Pan:Aabcv2240H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No. 229/Viz/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) Visakhapatnam Industrial Water V. Dy. Commissioner Of Income-Tax Circle – 5(1) Supply Company Limited Income Tax Office C/O. Gvmc, Room No. 204 Pratyakshakar Bhavan Teneti Bhavan, Asilmetta Junction Mvp Double Road Visakhapatnam – 530002 Visakhapatnam – 530017 Andhra Pradesh Andhra Pradesh [Pan:Aabcv2240H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS compliance for certain expenses and scope of disallowance under section 43B for interest payments. Assessing Officer passed another assessment order allowing the same loss as in the earlier assessment order. Once again Ld. CIT – 2, Visakhapatnam on 28.03.2014 holding the order of the Assessing Officer as erroneous and prejudicial to the interest of the revenue passed an order under