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.

41,770/- with a consequential tax liability of Rs. 3,73,754/- (after claiming 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

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.

41,770/- with a consequential tax liability of Rs. 3,73,754/- (after claiming 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

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.

41 cases also duly establishing their identity genuineness and also credit worthiness of those loan creditors with a particular emphasis to the fact that all those loan transactions were routed through BANKING CHANNEL: 5. Also considering the factual and legal and legal position recorded in depth in the annexed Statement of facts, it is humbly requested that the claim

THE VISAKHAPATNAM CO-OPERATIVE BANK LIMITED,,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), VISAKHAPATNAM

In the result, appeals filed by the assessee and Revenue are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

TDS prescribed under sub section (1) of that section. Clause (v) of section 194A(3), on which reliance was placed by the C.O.No.130 & 131/VIZ/2018 (M/s. The Visakhapatnam Co-op. Bank Ltd.) assessee, reads as under: 194A(3) The provisions of sub-section (1) shall not apply- ----- (v) to such income credited or paid by a co- operative society (other

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), , VISAKHAPATNAM vs. VISAKHAPATNAM CO-OPERATIVE BANK LIMITED, VISAKHAPATNAM

In the result, appeals filed by the assessee and Revenue are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

TDS prescribed under sub section (1) of that section. Clause (v) of section 194A(3), on which reliance was placed by the C.O.No.130 & 131/VIZ/2018 (M/s. The Visakhapatnam Co-op. Bank Ltd.) assessee, reads as under: 194A(3) The provisions of sub-section (1) shall not apply- ----- (v) to such income credited or paid by a co- operative society (other

THE VISAKHAPATNAM CO-OPERATIVE BANK LIMITED, ,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), VISAKHAPATNAM

In the result, appeals filed by the assessee and Revenue are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

TDS prescribed under sub section (1) of that section. Clause (v) of section 194A(3), on which reliance was placed by the C.O.No.130 & 131/VIZ/2018 (M/s. The Visakhapatnam Co-op. Bank Ltd.) assessee, reads as under: 194A(3) The provisions of sub-section (1) shall not apply- ----- (v) to such income credited or paid by a co- operative society (other

M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,ELURU vs. THE ITO, WARD-2, ELURU, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TDS and assessee failed to deduct the tax at source. Therefore, we do not have any hesitation to uphold the order of the Ld. CIT(A) and the assessee’s appeal on this ground is dismissed. 22. Ground Nos.5 & 6 are related to the addition of ` 12,52,25,946/- relating overdue interest on Non performing assets. This issue

M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,ELURU vs. THE ITO, WARD-2, ELURU, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TDS and assessee failed to deduct the tax at source. Therefore, we do not have any hesitation to uphold the order of the Ld. CIT(A) and the assessee’s appeal on this ground is dismissed. 22. Ground Nos.5 & 6 are related to the addition of ` 12,52,25,946/- relating overdue interest on Non performing assets. This issue

THE ACIT,, ELURU vs. M/S. THE DISTRICT CO - OPERATIVE CENTRAL BANK LTD., ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TDS and assessee failed to deduct the tax at source. Therefore, we do not have any hesitation to uphold the order of the Ld. CIT(A) and the assessee’s appeal on this ground is dismissed. 22. Ground Nos.5 & 6 are related to the addition of ` 12,52,25,946/- relating overdue interest on Non performing assets. This issue

THE ACIT., CIRCLE - 1, ELURU, ELURU vs. M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TDS and assessee failed to deduct the tax at source. Therefore, we do not have any hesitation to uphold the order of the Ld. CIT(A) and the assessee’s appeal on this ground is dismissed. 22. Ground Nos.5 & 6 are related to the addition of ` 12,52,25,946/- relating overdue interest on Non performing assets. This issue

THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,,ELURU vs. THE ACIT,, VISAKHAPATNAM

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TDS and assessee failed to deduct the tax at source. Therefore, we do not have any hesitation to uphold the order of the Ld. CIT(A) and the assessee’s appeal on this ground is dismissed. 22. Ground Nos.5 & 6 are related to the addition of ` 12,52,25,946/- relating overdue interest on Non performing assets. This issue

THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,,ELURU vs. THE ACIT,, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TDS and assessee failed to deduct the tax at source. Therefore, we do not have any hesitation to uphold the order of the Ld. CIT(A) and the assessee’s appeal on this ground is dismissed. 22. Ground Nos.5 & 6 are related to the addition of ` 12,52,25,946/- relating overdue interest on Non performing assets. This issue

THE ITO, WARD-2, ELURU, ELURU vs. M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD., ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

TDS and assessee failed to deduct the tax at source. Therefore, we do not have any hesitation to uphold the order of the Ld. CIT(A) and the assessee’s appeal on this ground is dismissed. 22. Ground Nos.5 & 6 are related to the addition of ` 12,52,25,946/- relating overdue interest on Non performing assets. This issue

SRINIVASA HAIR INDUSTRIES,ELURU vs. ASSISTANT COMMISSIONER OF INCOME TAX., ELURU

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.194/Viz/2018 (ननधधारण वर्ा/Assessment Year:2013-2014) M/S Srinivasa Hair Industries Asst.Commissioner Of P.B.No.8 Income Tax Eastern Street Circle-1 Eluru Eluru [Pan : Aalfs8434M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से/ Respondent By : Shri D.K.Sonowal, Citdr

section 41(1) of the Act. The Ld.AR argued that from very reading of the show cause notice issued by Pr.CIT it is established that the issue was verified by the AO. The Ld.AR referring to page No.28 of the paper book, submitted that the AO has called for the full details of purchases, opening stock and other expenses. Referring

SLC PROJECTS PVT.LTD.,,VISAKHAPATNAM vs. ACIT, CENTRAL CIRCLE-2, VISAKHAPATNAM

In the result, the appeal filed by the assessee is partly allowed for

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

41(2) or terminal loss allowable under section 32(1) (iii) . This amendment also strengthen the claim that now only detail for "block of assets" has to be maintained and not separately for each asset. 7.1 The above case law relied up on by the assessee does not help the assessee. The question in the instant case is whether

ACIT, CIRCLE-2(1), VISAKHAPATNAM vs. VIZAG SEAPORT PVT. LTD., VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon‟Ble & Shri S Balakrishnan, Hon‟Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No. 383/Viz/2017 (धनधाारणिर्ा/ Assessment Year : 2012-13) The Assistant Commissioner Of Vs. M/S. Vizag Seaport Pvt Ltd., Income Tax, Administrative Block, Circle-5(1), S4 Gallery, Port Area, Visakhapatnam. Visakhapatnam – 530035. (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent) [Pan :Aabcv2484K] अपीलाथी की ओर से/ Assessee By : Sri Fenil A Bhatt, Ar प्रत्याथी की ओर से/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुनिाई की तारीख/ Date Of Hearing : 15/02/2024 घोर्णा की तारीख/Date Of : /04/2024 Pronouncement O R D E R Pers. Balakrishnan:

1) of section 139'. This section 40(a)(ia) of the Act refers only to the duty to deduct tax and pay to government account. If there is any shortfall due to any difference of opinion as to the taxability of any item or the nature of payments falling under various TDS provisions, the assessee can be declared

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

41. These appeals are filed by the revenue against different orders of Learned Commissioner of Income Tax (Appeals), Visakhapatnam – 3 [hereinafter in short “Ld.CIT(A)”] vide respective DIN & Order No. as stated below:- ITA No. & A.Y. DIN & Order No. Dated ITBA/APL/S/250/2024-25/1072644049(1) 28.01.2025 (A.Y. 2019-20) ITBA/APL/S/250/2024-25/1072644910(1) 28.01.2025 (A.Y. 2020-21) ITBA/APL/S/250/2024-25/10726645302(1) 28.01.2025 (A.Y. 2021-22) ITBA/APL/S/250/2024-25/1072645352(1

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

41. These appeals are filed by the revenue against different orders of Learned Commissioner of Income Tax (Appeals), Visakhapatnam – 3 [hereinafter in short “Ld.CIT(A)”] vide respective DIN & Order No. as stated below:- ITA No. & A.Y. DIN & Order No. Dated ITBA/APL/S/250/2024-25/1072644049(1) 28.01.2025 (A.Y. 2019-20) ITBA/APL/S/250/2024-25/1072644910(1) 28.01.2025 (A.Y. 2020-21) ITBA/APL/S/250/2024-25/10726645302(1) 28.01.2025 (A.Y. 2021-22) ITBA/APL/S/250/2024-25/1072645352(1

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

41. These appeals are filed by the revenue against different orders of Learned Commissioner of Income Tax (Appeals), Visakhapatnam – 3 [hereinafter in short “Ld.CIT(A)”] vide respective DIN & Order No. as stated below:- ITA No. & A.Y. DIN & Order No. Dated ITBA/APL/S/250/2024-25/1072644049(1) 28.01.2025 (A.Y. 2019-20) ITBA/APL/S/250/2024-25/1072644910(1) 28.01.2025 (A.Y. 2020-21) ITBA/APL/S/250/2024-25/10726645302(1) 28.01.2025 (A.Y. 2021-22) ITBA/APL/S/250/2024-25/1072645352(1