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

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

VENKATA RAMANA GODA,VISAKHAPATNAM vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.489/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Venkata Ramana Goda, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Circle-3(1), Pan: Abzpg3216A Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 17/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 08/03/2025. The 2 Venkata Ramana Goda Vs. Acit

2. The Leamed CIT(A) ought to have appreciated that the notice u/s 148 issued by the Jurisdictional Assessing officer (JAO') u/s 148 is invalid in terms of section 151A as per which notice u/s 148 shall be issued through automated allocation by National Faceless Assessing Officer ('NFAC') and this action of JAO rendered the entire re- assessment proceedings void

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

ANDHRA PRADESH HOUSING BOARD,VIJAYAWADA vs. ACIT/DCIT, CIRCLE-1(1), VIJAYAWADA

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

2 I.T.A.No.732/VIZ/2025 Andhra Pradesh Housing Board of the same as well as deriving rental income and earing interest from bank deposits, had failed to filed its return of income for the year under consideration i.e. A.Y.2015- 16, initiated proceedings under section 147 of the Act. The AO passed an order under section 148A(d) of the Act, dated

LOKANADHA RAO BATHINA,VISAKHAPATNAM vs. INCOME-TAX OFFICER, WARD-3(2), 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.283/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2016-17) Lokanadha Rao Bathina Vs. Income Tax Officer D.No.54-11-33/3/1, Aditya Nagar Ward-3(2) Isukathota-530013 Infinity Towers, Andhra Pradesh Shankaramattam Road [Pan :Apqpb9831H] Visakhapatnam - 530016 (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

148 of the Act, dated 01.05.2018 and 143(2) of the Act, dated 06.11.2019 were issued and served on the assessee. In response to the notice, the assessee submitted information on various dates. During the year under review, the assessee entered into a sale agreement jointly for purchase of land along with three others Bathina Rajyalakshmi, M.Sridevi and M.AdiSankar

NANNEBOYINA KALYAN CHAKRAVARTHY,VISAKHAPATNAM vs. INCOME TAX OFFICER, (WARD IT), VIJAYAWADA

In the result, appeal of the assessee is allowed

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.104/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2016-17) Nanneboyina Kalyan Chakravarthy V. Income Tax Officer C/O. C.R. Hemanthkumar Ward International Taxation Cr Building, 1St Floor Annex. H.No 9-14-4/7, Flat No. 7 M.G. Road, Vijayawada Sowbhagyaapartments Andhra Pradesh – 520002 Cbm Compound, Vip Road Andhra Pradesh - 530003 [Pan: Cuepk3530P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS Statement – payment made to ICICI Bank Ltd., Rs. 78,133/- Non-residents 3. Ld. AO observed that assessee has not filed his return of income for the assessment year under consideration, he therefore considered the above transactions as income escaping the assessment and issued show-cause notice under section 148A(b) to the assessee on 07.03.2023. In response, assessee

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED, VISAKHAPTNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS, it cannot be considered genuine that the expenditure has been incurred by the assessee-company for the sub-contracts undertaken by the assessee-company. Further it is also found that the Managing Director has repeatedly accepted the bogus nature of sub-contract works in the sworn statement. We are therefore of the considered view that the order

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), , VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED,, VISAKHAPATNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS, it cannot be considered genuine that the expenditure has been incurred by the assessee-company for the sub-contracts undertaken by the assessee-company. Further it is also found that the Managing Director has repeatedly accepted the bogus nature of sub-contract works in the sworn statement. We are therefore of the considered view that the order

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED, VISAKHAPTNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

TDS, it cannot be considered genuine that the expenditure has been incurred by the assessee-company for the sub-contracts undertaken by the assessee-company. Further it is also found that the Managing Director has repeatedly accepted the bogus nature of sub-contract works in the sworn statement. We are therefore of the considered view that the order

GUNTUPALLI NAGESWARA RAO,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 1(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

TDS of Rs. 1,86,790/-). Page. No 2 I.T.A.No.378 & 379/VIZ/2025 Guntupalli Nageswara Rao 4. Thereafter, the AO issued a notice under section 148A(b) of the Act calling upon the assessee to place on record documentary evidence to support his claim for multi- facet deductions viz., (i) Loss on house property: Rs. 2,00,000/-; (ii) Deduction under

GUNTUPALLI NAGESWARA RAO,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 1(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

TDS of Rs. 1,86,790/-). Page. No 2 I.T.A.No.378 & 379/VIZ/2025 Guntupalli Nageswara Rao 4. Thereafter, the AO issued a notice under section 148A(b) of the Act calling upon the assessee to place on record documentary evidence to support his claim for multi- facet deductions viz., (i) Loss on house property: Rs. 2,00,000/-; (ii) Deduction under

SRI TIRUMALA ESTATES AND FARMLANDS,VISAKHAPATNAM vs. ACIT, CENTRAL CIRCLE-1, VISAKHAPATNAM

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

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

148 of the Act. Subsequently, a notice under Section 142(1) of the Act, dated 15.11.2021 was issued, calling for relevant information, but there was no response from the assessee. Therefore, the A.O. completed the assessment to the best of his judgment under Section 144 of the Income Tax Act, 1961 read with Section 147 of the Act, and determined

SRI TIRUMALA ESTATES AND FARMLANDS,VISAKHAPATNAM vs. ACIT, CENTRAL CIRCLE-1, VISAKHAPATNAM

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

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

148 of the Act. Subsequently, a notice under Section 142(1) of the Act, dated 15.11.2021 was issued, calling for relevant information, but there was no response from the assessee. Therefore, the A.O. completed the assessment to the best of his judgment under Section 144 of the Income Tax Act, 1961 read with Section 147 of the Act, and determined

RP TRANSPORTERS, ,VIJAYAWADA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), , VIJAYAWADA

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru R L Reddy, Hon’Ble & Shri S. Balakrishnan, Hon'Ble

148 of the Act, the assessee replied that it had filed its return of income for the AY 2011-12 on 29/09/2011 and requested to treat the same as return of income filed in response to notice u/s.148 of the Act. Accordingly, notices u/s. 143(2) and 142(1) were issued to the assessee. In response to the notices

SUBBA RAO JALADI,GUNTUR vs. INCOME TAX OFFICER, WARD-2(1), GUNTUR

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

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

2,00,000/- or more, with a banking Company Valued at Rs. 5,28,40,000/-. ii. Deposited Cash of Rs. 10,00,000 or more in a Saving Bank Account Valued at Rs. 4,24,50,900/-. iii. TDS Return - Payment to Contractor (Section 194C) Valued at Rs. 5,03,950/- 3. Assessing Officer observed that

THE YANAM CO OPERATIVE STORES LIMITED,YANAM vs. PRINICIPAL COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.360/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) The Yanam Cooperative Stores Limited V. Pr.Cit 3-2-058, Vishnalayam Street Aayakar Bhavan Dabagarden – 530020 Yanam – 533464 Visakhapatnam Puducherry Andhra Pradesh [Pan: Aadft3518R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

148 of the Act and has accepted the income declared by the assessee as Nil while framing the assessment under section 147 r.w.s. 144B of the Act. There is merit in the argument of the Ld.AR that when Page No. 4 I.T.A.No.360/VIZ/2024 The Yanam Cooperative Stores Limited the income is assessed as NIL, the assessee is entitled

SRI KOTI LINGA HARI HARA MAHAKSHETRAM TEMPLE,VISAKHAPATNAM vs. INCOME TAX OFFICER, EXEMPTION WD, RAJAHMUNDRY

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.365/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Sri Koti Linga Hari Hara Vs. Income Tax Officer, Mahakshetram Temple, Exemption Ward, Visakhapatnam. Rajahmundry. Pan: Acgfs3064C (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Cr Hemanth Kumar, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/11/2025 Hearing: घोषणा की तारीख/Date Of 07/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

148 of the Income-tax Act, 1961 is bad in law, being contrary to the third proviso to section 12A(2). Consequently, the reassessment framed on such an incorrect foundation is illegal, void ab initio, and without jurisdiction. 3. The Ld. Commissioner of Income Tax (Appeals) failed to appreciate that the appellant, being a temple governed by the Endowments Department

DEPUTY COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. NS HEALTHCARE SERVICES PRIVATE LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred as a personal expenditure of the Directors. Page No. 4 I.T.A.Nos.145, 146, 147 & 148/VIZ/2025 I.T.A.Nos.184, 185, 186 & 187/VIZ/2025 M/s. NS Healthcare Services Private Limited 6. Further, Ld. AO also considered an amount of Rs.2