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

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

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\n[in short

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

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

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

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

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

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

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VIJAYAWADA

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

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

iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses cannot be allowed which has been incurred

THE ITO(TDS) WARD-3(3), GUNTUR vs. THE EXECUTIVE ENGINEER, RURAL WATER SUPPLY PROJECT,,

In the result, appeal of the revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीऱ सं./I.T.A.No.511/Viz/2013 & 512/Viz/2013 (निर्धारण वषा / Assessment Year : 2011-12 & 2012-13) Income Tax Officer (Tds) Vs. Executive Engineer Ward-3(3) Rural Water Supply Project Guntur Viswanadhapuram Podili, Prakasam Dist. [Pan : Hydro2981G] (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Co No.132 & 133/Viz/2013 (Arising Out Of Ita No.511 & 512/Viz/2013) (निर्धारण वषा / Assessment Year : 2011-12 & 2012-13) Executive Engineer Vs. Income Tax Officer (Tds) Rural Water Supply Project Ward-3(3) Viswanadhapuram Guntur Podili, Prakasam Dist. [Pan : Hydro2981G] (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

26 mandals duly covering 5 assembly constituencies and it is essential to supply water to the public on emergency basis where the schemes defunct In view of such an emergency, and as they have a norm of allotment the works to rural poor, who are immediately available and work with dedication, since they belong to the areas of work

SRI SEETARAMANJANENYA SORTEX,KAKINADA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.147/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2018-19) Sri Seetaramanjaneya Sortex Vs. Principal Commissioner Of 1-2015/A, Uppalanka Income Tax Kakinada Visakhapatnam [Pan : Abdfs4641P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

iii) of I.T.Act, TDS is not applicable on interest paid to banking company and interest of Rs.2,448/- paid to ECL finance Limited does not attract TDS provision as the interest amount does not exceed the threshold limit as specified in section 194A(3)(i)(d) of I.T.Act. In support of the same, the assessee has not furnished any documentary

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. SRI NARASIMHARAJU KANUMURI, VISAKHAPATNAM

In the result, the appeal filed by the revenue in ITA No

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.267/Viz/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Deputy Commissioner Of Vs. Sri Narasimharaju Income Tax, Kanumuri, Visakhapatnam. Visakhapatnam. Pan: Aerpk2717F (Appellant) (Respondent)

iii) payments made by the assessee (except for Rs.56,26,500/-) were to resident sellers or to the intermediary who had the right to get the land registered in his name or in the name of his nominee, and, thus, such payments were not payments to a non-resident within the meaning of Section

VISAKHAPATNAM PORT AUTHORITY,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

26,11,019 2. Disallowance of excess claim of depreciation 6,35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. M/S. VISAKHAPATNAM PORT AUTHORITY, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

26,11,019 2. Disallowance of excess claim of depreciation 6,35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

26,11,019 2. Disallowance of excess claim of depreciation 6,35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1