SMT. L SUDHA BALA, L/R OF LATE SRI L.NARSA REDDY,GUNTUR vs. THE DCIT, SPECIAL RANGE GUNTUR, GUNTUR

In the result, the appeals of the assessee are dismissed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.260 & 261/Viz/2012 (धििाारण िर्ा/ Assessment Years :1984-85 & 1985-86 Respectively) L.Sudha Bala Vs. Dy.Commissioner Of L/R Of Late Sri L Narasa Reddy Income Tax Prop.Sri Venkateswara Agro Chemicals Special Range Industries Guntur 2-14-101, Syamala Nagar 2Nd Lane, Guntur [Pan : Acgpl2351P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 40A(3) of the Act. The AO made the addition alternately u/s 40A(3) of the Act also. The AO made the addition of the same amount on both the grounds of disallowance u/s 40A3 as well as the bogus purchases

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:

bogus transactions to the tune of Rs. 4,99,65,247/- with M/s. A.K. Capital Enterprises and M/s. Vihan Enterprises initiated proceedings under section 147 of the Act. Thereafter, an order under section 148A(d) of the Act, dated 29/03/2023, was passed, and a notice under section 148 of the Act, dated 29/03/2023, was issued by the AO. 3. During

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

INCOME TAX OFFICER, WARD-1(2), VIJAYAWADA vs. BOMMISETTY VENKATA SIVA KUMAR, VIJAYAWADA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.238/Viz/2023 ("नधा"रण वष" / Assessment Year :2014-15) The Income Tax Officer, Vs. Sri Bomisetty Venkata Siva Ward-1(1), 2Nd Floor, Kumar, Prop. M/S. Bommisetty C.R. Buildings, Mg Road, Sambasiva Rao Trading Vijayawada – 522002. Company, 1-4-221-2, Rtc Workshop Road, Bhavanipuram, Vijayawada-522012. Pan: Addpb 9483 C (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Gvn Hari, Ar ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr

section 40A(3) of the Act. Further, the Ld. AR also submitted that these purchases cannot be treated as bogus

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

section 132(4A) that deem that the contents of the seized material are true.” 53. On the above grounds, the Ld. AR argued that the assessee has purchased tobacco from grey market by cash which was already included in the purchases while admitting the gross profit during the filing of return of income. The Ld. AR admitted that this grey

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

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

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

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

bogus purchases and capitalization of the same while framing the scrutiny assessment. However, while framing the assessment U/s. 143(3) r.w.s 153A of the Act, the Ld. AO observed that the assessee has resorted to inflation of capital expenditure to claim depreciation and interest on the Term Loan. It is a settled law that when section