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

capital gains (STCG): Rs.61,60,000/-. 9. The assessee, being aggrieved with the order of the CIT(A) has carried the matter in appeal before us. 10. We have heard the Learned Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements 8 Venkata Ramana

INCOME TAX OFFICER, WARD 3(3) , VISAKHAPATNAM vs. MEENA TANGUDU, VISAKHAPATNAM

In the result, appeal of the revenue is partly allowed

1,20,000/- under Chapter VIA\nof the Act. The case has been selected for limited scrutiny under CASS for\nexamining the Deduction / exemption claimed from capital gains. Accordingly,\nstatutory notices under section 143

BALA VENKATA KATYAYANI DASU,ELURU vs. INCOME TAX OFFICER, CIRCLE-1, RAJAMAHENDRAVARAM

Bench: Us:

Section 143(1) of the Act, comprised of, viz. (i). agriculture income: Rs. 40,000/-; (ii). short-term capital gain

SANTOSH AGRAWAL,CHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRLCE-1, VISAKHAPATNAM

capital gains and other sources, filed return of\nincome for the A.Y. 2006-07 admitting a total income of Rs. 3,68,980/-. The\nreturn was summarily processed under section 143(1

ASHOK KUMAR AGRAWAL,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

capital gains and other sources, filed return of\nincome for the A.Y. 2006-07 admitting a total income of Rs. 3,68,980/-. The\nreturn was summarily processed under section 143(1

SATYANARAYANA VISWANADHA,MACHILIPATNAM vs. INCOME TAX OFFICER, WARD-1, MACHILIPATNAM

In the result, appeal filed by the assessee is allowed

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.223/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2012-13) Satyanarayana Viswanadha V. Ito – Ward – 1 Machilipatnam D.No. 21/411, Bhaskarapuram Krishna District - 521001 Machilipatnam – 521001 Andhra Pradesh Krishna District Andhra Pradesh [Pan: Aatpv0775E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 143(2) and 142(1) of the Act were issued and served on the assessee, calling for relevant information. In response, assessee furnished replies vide letters dated 17.09.2019 & 29.10.2019. Further, Ld. Assessing Officer [hereinafter in short “Ld. AO"] issued notice on 03.12.2019 requesting the assessee to show cause as to why the long-term capital gain

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. RAJA RAO PARACHURI, VISAKHAPATNAM

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.374/Viz/2024 (िनधा"रण वष"/Assessment Year: 2013-14) Deputy Commissioner Of Vs. Raja Rao Parachuri, Income Tax, Visakhapatnam. Visakhapatnam. Pan: Aatpp2493B (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: P. Murali & Co राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of 07/08/2025 Hearing: घोषणा की तारीख/Date Of 08/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

Section 143(3) r.w.s 147 of the Act, dated 30.10.2019, determined the income of the assessee at Rs. 13,10,30,550/- after making two additions, viz. (i). Long-term capital gains (on JDA): Rs. 11,26,01,500/-; and (ii) Unexplained cash deposits: Rs. 10,50,000/-. 5 DCIT vs. Raja Rao Parachuri 5. Aggrieved, the assessee carried

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. VENKATA SITA RAMACHANDRA RAO KANCHUMARTHY, RAJAHMUNDRY

In the result, appeal of the revenue is dismissed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.352/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2016-17) Vs. Dy. Commissioner Of Income Tax Venkata Sita Ramachandra Rao Kanchumarty International Taxation, Circle H.No. 26-22-16 Ground Floor, Infinity Tower Near Chinna Anjaneya Swamy Temple Sankarmattam Road Danavaipeta, Rajahmundry Visakhapatnam – 530016 East Godavari District – 533103 Andhra Pradesh Andhra Pradesh [Pan:Edzpk3519Q]

section 143(2) and 142(1) of the Act assessee’s representatives filed requisite information called for. Ld.Assessing Officer [hereinafter in short “Ld. AO"] during the course of scrutiny proceedings recomputed the Long-Term Capital Gains

GANGUNAIDU SABBAVARAPU,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-2(5), VISAKHPATNAM

capital gain” in his\nrevised return of income for the subject year. However, the CIT(A) did\nnot find favour with the claim of the assessee. The CIT(A) held a firm\nconviction that as the scope of jurisdiction u/s 143(1) of the Act is\nlimited to carrying out of prima facie adjustments contemplated under\nthe said statutory provision

AGRI GOLD FOODS AND FARM PRODUCTS LIMITED,VIJAYAWADA vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

Bench: Us:

capital gain of Rs.13.26 crores (supra) disclosed by the assessee company on sale of the subject agricultural 9 Agri Gold Foods and Farm Products Limited land and was accepted in the course of the original assessment, inter alia, on two grounds viz., (i). that the reopening of the reassessment by the successor A.O. based on a “change of opinion

VIDYAVATHI MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

capital gains at Rs. 5,435/-. The Ld. AO thus completed the assessment U/s. 143(3) r.w.s 147 of the Act on 19/03/2022 assessing the total income at Rs. 7,80,035/-. 3. Thereafter, by virtue of the powers vested U/s. 263 of the Act, the Ld. CIT (IT & TP), Hyderabad considered the order of the Ld. AO passed

SIVAKAMA SUNDAR MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

capital gains at Rs. 5,435/-. The Ld. AO thus completed the assessment U/s. 143(3) r.w.s 147 of the Act on 19/03/2022 assessing the total income at Rs. 7,80,035/-. 3. Thereafter, by virtue of the powers vested U/s. 263 of the Act, the Ld. CIT (IT & TP), Hyderabad considered the order of the Ld. AO passed

LINTON PROJECTS PRIVATE LIMITED,VIZIANAGARAM vs. THE INCOME TAX OFFICER, WARD-1, , VIZIANAGARAM

In the result, appeal of the revenue is dismissed in limine and Cross objection filed is assessee is dismissed as infructuous

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

Capital amounting to Rs. 89,67,000/- from various relatives of the Directors of the company, the Assessing Officer treated the share investments as ingenuine and added the same as unexplained cash credit under section 68 of the Act on protective basis as admitted by the assessee before the Investigation Directorate as her unexplained investment under section

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISAKHAPATNAM vs. POOSARLA SATYAVATHI, VIZIANAGARAM

In the result, appeal of the revenue is dismissed in limine and Cross objection filed is assessee is dismissed as infructuous

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

Capital amounting to Rs. 89,67,000/- from various relatives of the Directors of the company, the Assessing Officer treated the share investments as ingenuine and added the same as unexplained cash credit under section 68 of the Act on protective basis as admitted by the assessee before the Investigation Directorate as her unexplained investment under section

DR KONDABOLU BASAVAPUNAIAH & DR LAKSHMI PRASAD TRUST,GUNTUR vs. INCOME TAX OFFICER (EXEMPTION WARD), GUNTUR

Capital Gains, along with a variation in purchase value of Rs.\n17 lakhs, and an amount of Rs. 8,56,330/-under the head Income from\nBusiness.\n7.\nWithout prejudice to the grounds mentioned above, and assuming,\nwithout conceding, that there was a violation of section 13(1)(c) r.w.s

PUPPALA GOPI KRISHNA,GUNTUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, GUNTUR

In the result, appeal of the assessee is allowed

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

capital gains [LTCG] on sale of vacant site. In the computation submitted before the Ld. AO, the assessee offered net LTCG of Rs. 1,04,74,973/- after deducting the indexed cost of acquisition and the cost of improvement aggregating to Rs. 1,26,84,027/- and accordingly revised the total income of Rs. 1,22,84,430/-. Under these

MADHU DEVI,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-2(1), VIJAYAWADA

capital gains. The Assessing Officer initiated penalty proceedings under Section 271D for contravening Section 269SS of the Income Tax Act, 1961, imposing a penalty.", "held": "The Tribunal held that the assessees, being senior citizens, were not aware of the amendment to Section 269SS and that there was no suppression of cash receipts. The Tribunal also noted that the Assessing Officer

SAI SRI ANUSHA VALLURU,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

1.\nThat, on the facts and in the circumstances of the case, and in law,\nthe order dated 30.04.2024 passed by the Ld. CIT (Appeals), NFAC,\nconfirming the assessment order passed U/S 143(3) r.w.s. 147 of the IT Act,\nby the Deputy Commissioner of Income Tax, Circle-2, Vijayawada, dt\n28.12.2016, is erroneous, bad in law, and liable