DCIT, CENTRAL CIRCLE-1, VISAKHAPATNAM vs. GVA INDUSTRIES PVT. LTD., DHAMTARI

3\nI.T.A.Nos.137, 138 & 139/VIZ/2025\nI.T.A.Nos.221, 222 & 223 /VIZ/2025\nM/s. GVA Industries Private Limited --\nincome in response to notice under section148 of the Act. Subsequently, notice\nunder section 143(2) of the Act was issued on 22.11.2021. In the statement\nrecorded during the survey proceedings, the three suppliers have stated that they\nhave never supplied any material and have

GVA INDUSTRIES PRIVATE LIMITED,CHHATTISGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

3\nI.T.A.Nos.137, 138 & 139/VIZ/2025\nI.T.A.Nos.221, 222 & 223 /VIZ/2025\nM/s. GVA Industries Private Limited --\nincome in response to notice under section148 of the Act. Subsequently, notice\nunder section 143(2) of the Act was issued on 22.11.2021. In the statement\nrecorded during the survey proceedings, the three suppliers have stated that they\nhave never supplied any material and have

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

13-12- 1996, the officer concerned, on his own admission, had no locus standi in the matter. Moreover, the Panchnama made on that date had many defects as admitted by the department itself. Thus, no fault could be found with the impugned order of the Tribunal. The impugned assessment indeed was barred by limitation and also invalid.” 21. Respectfully following

DCIT, CENTRAL CIRCLE-1, VISAKHAPATNAM vs. GVA INDUSTRIES PVT. LTD., DHAMTARI

3\nI.T.A.Nos.137, 138 & 139/VIZ/2025\nI.T.A.Nos.221, 222 & 223 /VIZ/2025\nM/s. GVA Industries Private Limited --\nincome in response to notice under section148 of the Act. Subsequently, notice\nunder section 143(2) of the Act was issued on 22.11.2021. In the statement\nrecorded during the survey proceedings, the three suppliers have stated that they\nhave never supplied any material and have

DCIT, CENTRAL CIRCLE-1, VISAKHAPATNAM vs. GVA INDUSTRIES PVT. LTD., DHAMTARI

3\nI.T.A.Nos.137, 138 & 139/VIZ/2025\nI.T.A.Nos.221, 222 & 223 /VIZ/2025\nM/s. GVA Industries Private Limited --\nincome in response to notice under section148 of the Act. Subsequently, notice\nunder section 143(2) of the Act was issued on 22.11.2021. In the statement\nrecorded during the survey proceedings, the three suppliers have stated that they\nhave never supplied any material and have

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

3, 9, 12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

3, 9, 12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

3, 9, 12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

3, 9, 12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

3, 9, 12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased

GVA INDUSTRIES PRIVATE LIMITED,CHHATTISGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

3\nI.T.A.Nos.137, 138 & 139/VIZ/2025\nI.T.A.Nos.221, 222 & 223 /VIZ/2025\nM/s. GVA Industries Private Limited\nincome in response to notice under section148 of the Act. Subsequently, notice\nunder section 143(2) of the Act was issued on 22.11.2021. In the statement\nrecorded during the survey proceedings, the three suppliers have stated that they\nhave never supplied any material and have