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 :

ii) Unexplained cash deposits: Rs. 10,50,000/-. 5 DCIT vs. Raja Rao Parachuri 5. Aggrieved, the assessee carried the matter in appeal before the CIT(A), who allowed the same. For the sake of clarity, the observations of the CIT(A) are culled out as under: “5.1. The appellant is an individual and filed his return of income

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

35,77,240/-.\n7. Aggrieved, the assessee carried the matter in appeal before the\nCIT(A). The assessee, inter alia, had claimed before the CIT(A) that the\ncompensation received by him on the compulsory acquisition of his land\nas per the award u/s 3E(1) of the National Highways Act, 1956, bearing\nAward No. 8 of 2022, dated

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

35-39 Accepted DEVI Bankers Share Cheque Capital Investment 4 PBS BHARATHI 1,85000 8,32,500 10,17,500 Through Yes Yes Yes 54-55 Accepted Bankers Share Cheque Capital Investment 5 PBS 1,85000 8,32,500 10,17,500 Through Yes Yes Yes 56-57 Accepted VENKATESWARA Bankers Share RAO Cheque Capital Investment 6 POOSARLA ARUNA 1

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

35-39 Accepted DEVI Bankers Share Cheque Capital Investment 4 PBS BHARATHI 1,85000 8,32,500 10,17,500 Through Yes Yes Yes 54-55 Accepted Bankers Share Cheque Capital Investment 5 PBS 1,85000 8,32,500 10,17,500 Through Yes Yes Yes 56-57 Accepted VENKATESWARA Bankers Share RAO Cheque Capital Investment 6 POOSARLA ARUNA 1

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. VIZAG RE-BARS PRIVATE LIMITED, VISAKHAPATNAM

In the result, the cross objection filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

Capital Gains on sale of shares. 3. The learned Commissioner of Income-Tax (Appeals) ought to have quashed the notice u/s 148 even on the ground that: a) The notice issued was not based on the facts stated in the return of income. b) The notice issued u/s 148A(b) is void ab initio as the grounds mentioned therein were

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

UPPADA KESAVAJANARDHANA RAO,FLORIDA, USA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION, , VISAKHAPATNAM

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A. No. 40/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2016-17) Uppada Kesavajanardhana Rao V. Asst. Cit 7266, Chelsea Harbor Dr International Taxation Orlando, Florida, Usa – 32829 Income Tax Office, Infinity Towers Sankaramatam Road Usa - 322829 Visakhapatnam - 530016 [Pan :Aiipk6712H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदधतध कध प्रनतनिनर्त्व / Assessee Represented By : Mrs. Hema Latha K., Ar रधजस्व कध प्रनतनिनर्त्व / Department Represented By : Dr. Aparna Villuri, Sr.Ar

35: Ground no 4 before CIT(A) “The Ld. Assessing Officer is not justified in computing the short term capital gains at Rs.1,83,71,987/- as against short term capital gains of Rs.99,76,950/- returned by assessee.” Issue “With respect to the sale consideration arrived by AO by including the Stamp duty Value of UDS / land

INCOME TAX OFFICER, WARD-2(1), GUNTUR vs. SHIVANI COTTON INDUSTRIES PRIVATE LIMITED, GUNTUR

In the result, appeals ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ii) on merits. The learned CIT(A) disposed of the appeal filed by the assessee and deleted the additions made by the Assessing Officer towards advance given to M/s. Jaya Balajee Real Media Private Limited on the ground that, the ‘substantive addition’ made in the hands of M/s. Jaya Balajee Real Media Private Limited has been confirmed by the learned

INCOME TAX OFFICER, WARD- 1(1),, GUNTUR vs. POTTI KUMARA NAGA VENKATA SAI CHAKRAVARTHY, GUNTUR

In the result, appeals ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ii) on merits. The learned CIT(A) disposed of the appeal filed by the assessee and deleted the additions made by the Assessing Officer towards advance given to M/s. Jaya Balajee Real Media Private Limited on the ground that, the ‘substantive addition’ made in the hands of M/s. Jaya Balajee Real Media Private Limited has been confirmed by the learned

INCOME TAX OFFICER, GUNTUR vs. MADHUSUSHANA VENKATA SUBBA RAO POTTI, GUNTUR

In the result, appeals ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ii) on merits. The learned CIT(A) disposed of the appeal filed by the assessee and deleted the additions made by the Assessing Officer towards advance given to M/s. Jaya Balajee Real Media Private Limited on the ground that, the ‘substantive addition’ made in the hands of M/s. Jaya Balajee Real Media Private Limited has been confirmed by the learned

ASSISTANT COMMISSIONER OF INCOME TAX , GUNTUR vs. MS.VIJAYASAI LAKSHMI SRINIVASA COTTON MILLS, GUNTUR

In the result, appeals ITA

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ii) on merits. The learned CIT(A) disposed of the appeal filed by the assessee and deleted the additions made by the Assessing Officer towards advance given to M/s. Jaya Balajee Real Media Private Limited on the ground that, the ‘substantive addition’ made in the hands of M/s. Jaya Balajee Real Media Private Limited has been confirmed by the learned

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)

ii) the resident sellers had earlier entered into an unregistered sale agreement dated 02.01.2016 with the NRIs; (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

INCOME TAX OFFICER, INFINITY TOWERS, SANKARMATHAM ROAD vs. AMMAJI CHENNUPATI, RAJEEVNAGAR, KURMANNAPALEM

In the result, the appeal of the revenue is dismissed, while the additional ground of cross-objection of the assessee is allowed in terms of our aforesaid observations

Bench: Us:

Capital Gains on sale of shares as unexplained. 4 ITA No.441/Viz/2024 & CO No.7/Viz/2025 Ammaji Chennupati 3. Any other grounds of Cross-Objection that may the raised at the time of hearing. Further, the assessee cross-objector has raised an additional ground which reads as under: “1. On the facts and in the circumstances of the case, the notice issued

VULLI RADHAKRISHNA,TUNI vs. INCOME TAX OFFICER, WARD-1, TUNI

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.359/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Vulli Radhakrishna, Vs. Income Tax Officer, Tuni. Ward-1, Pan: Aegpv1751H Tuni. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 17/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short “A.O.”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short “The Act”) Dated 26/03/2022 For Assessment Year (Ay) 2015-16. 2 Vulli Radhakrishna Vs. Ito

35,451/- after making certain additions, viz. (i) addition of unexplained deposits under section 69A of the Act: Rs. 28,82,633/-; (ii) addition of unexplained payment of credit cards bills: Rs.11,79,160/-; (iii) unexplained investment towards purchase of equity shares: Rs.3,76,565/-; and (iv) short term capital gains (STCG) on sale of equity shares: Rs.1

GADIRAJU JHANSIRANI,CHINNAMIRAM vs. INCOME TAX OFFICER, WARD-2, BHIMAVARAM

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated hereinabove

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.253/Viz/2024 (िनधा"रण वष" / Assessment Year : 2014-15) Gadiraju Jhansirani, Vs. Income Tax Officer, Chinnamiram. Ward-2, Pan: Bqjpg8177J Bhimavaram. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Smt. A. Aruna, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 15/07/2024 घोषणा क" तारीख/Date Of : 25/07/2024 Pronouncement O R D E R

section 54F of the Act. In response, the assessee’s Representative filed his objections which are extracted by the Ld. AO in his order at pages 3, 4 & 5 and the crux of the issues raised by the assessee in her objection before the Ld. AO is as under: “i) The amendment made in the Finance Act, 2014 in respect

DEPUTY COMMISSIONER OF INCOME TAX (IT), VISAKHAPATNAM vs. SHRI APPARAO MUKKAMALA, USA

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

capital gains (LTCG) on sale of shares of M/s Sunbeam Hospitality Pvt. Ltd. The return of income filed by the assessee was initially processed as such under section 143(1) of the Act. 3. On 26.02.2019, search and seizure proceedings were conducted in the case of M/s Sandhya Hotels Pvt. Ltd. During the course of the search proceedings, a copy

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

gains of business or profession” wherein the disallowance U/s. 43B has been made becomes irrelevant and as such no consequentialeffect would be given to the disallowed amount on payment basis in the subsequent year. Therefore, the Ld. CIT-1, Visakhapatnam was of the opinion that such expenditure having no correlation with the income of the assessee earned during the relevant

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

gains of business or profession” wherein the disallowance U/s. 43B has been made becomes irrelevant and as such no consequentialeffect would be given to the disallowed amount on payment basis in the subsequent year. Therefore, the Ld. CIT-1, Visakhapatnam was of the opinion that such expenditure having no correlation with the income of the assessee earned during the relevant