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34 results for “capital gains”+ Section 84(1)clear

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Key Topics

Section 143(3)20Section 14A20Addition to Income16Section 143(2)14Section 80I12Capital Gains12Section 14810Section 14710Section 263

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

ITA 489/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2020-21

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

For Appellant: Mrs. K. Hemalatha, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133(6)Section 147Section 148Section 151ASection 2(14)(iii)

Showing 1–20 of 34 · Page 1 of 2

8
Section 271(1)(c)8
Disallowance6
Deduction4
Section 234A
Section 234B
Section 250

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

SANNIDHI SRI RAMACHANDRA MURTHY (HUF),RAJAHMUNDRY vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

In the result, appeal of the assessee is allowed

ITA 230/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam25 Sept 2024AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A. No. 230/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2013-14) Sannidhi Sriramachandra Murthy (Huf) V. The Assistant Commissioner Of D.No. 42-10-30/31 Income Tax, Circle-1 Income Tax Office, Aayakar Bhavan Sree Ramachandra Murthy Nilayam Veerabhadrapuram Mangalavarapu Peta Rajahmundry-533105 Rajahmundry – 533101 Andhra Pradesh Andhra Pradesh [Pan: Aaxhs4350L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व / Assessee Represented By : Shri Gvn Hari, Ar राजस्व का प्रतततितित्व / Department Represented By : Dr. Satyasaai Rath, Cit(Dr)

Section 147Section 148Section 263Section 45(2)Section 54BSection 54ESection 54F

84,56,550/- ii. Deduction under section 54F of the I.T. Act claimed by the assessee for Rs. 1,15,67,647/- 5. Aggrieved by the order of the Ld. Pr.CIT assessee is in appeal before us by raising following grounds of appeal: - 1. The order of the learned Principal Commissioner of Income Tax is contrary to the facts

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

In the result, appeal of the assessee is allowed

ITA 82/VIZ/2021[2016-17]Status: DisposedITAT Visakhapatnam17 Oct 2023AY 2016-17

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

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Satya Sai Rath, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 263Section 269SSection 271(1)(c)Section 271D

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

NAGESWARA RAO VISWANADHA,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed

ITA 213/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam10 Jan 2024AY 2016-17

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

For Appellant: Sri GVN Hari, ARFor Respondent: Sri Madhukar Aves, Sr. AR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 50CSection 50C(2)Section 50C(3)

capital gains under the provisions of section 50C of the Act is outside the scope of the limited scrutiny for which the case was selected. 3. The Ld. CIT(A) ought to have held that the provisions of section 50C of the Act are not applicable in respect of the property sold by the appellant to Viswanadha Educational Society

MADDIMISETTI SRINIVASU,TANUKU vs. THE ASST . COMMISSIONER OF INCOME TAX,CIRCLE-1, RAJAHMUNDARY

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

ITA 96/VIZ/2022[2017-2018]Status: DisposedITAT Visakhapatnam31 Jan 2023AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.96/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2017-18) Maddimsetti Srinivasu Vs. Asst.Commissioner Of D.No.1-77, Peddintlamma Street Income Tax Tanuku Mandal Circle-1 Komaravaram Rajahmundry [Pan : Ctxpm3066Q]

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri M.N.Murthy Naik, CIT(DR)
Section 142(1)Section 143(3)Section 263Section 45(2)Section 48Section 54F

84,160/- under the heads ‘income from capital gains’ and 2 ITA No.96/Viz/2022, A.Y.2017-18 Maddimsetti Srinivasu.,Komaravaram ‘other sources’. The case was selected for scrutiny under CASS to verify the issue of ‘high value of cash withdrawals during the year’. Accordingly, notices u/s 142(1) and 143(2) of the Income Tax Act, 1961 (in short ‘Act’) were issued

YALAVARTHY PADMA PRIYA,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-2(3), VIJAYAWADA

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

ITA 350/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam15 Oct 2024AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A. No. 350/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19) Yellavarthy Padma Priya V. Income Tax Officer – Ward – 2(3) Income Tax Office D.No. 48-6-6/5, Flat No. 401 C.R. Building, M.G. Road Sri Sai Plaza, Basavapunnaiah Street Vijayawada Gunadala Vijayawada – 520005 Andhra Pradesh [Pan: Adapy6673L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 142(1)Section 143(2)Section 147Section 148Section 148A

section 148A(b) of the Act dated 31.03.2022. It was noticed that the assessee has sold the impugned property for a consideration of Rs.1,42,44,000/- on 12.09.2017 which was misreported as Rs.2,84,88,.000/- in the notice. Assessee has offered long term capital gain of Rs. 1

VIJAYA DURGA PENUMALA,RAJAHMUNDRY vs. THE INCOME TAX OFFICER, WARD-2(1), RAJAHMUNDRY

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

ITA 238/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam31 Jul 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.237/Viz/2024 (िनधा"रण वष" / Assessment Year :2016-17)

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(2)Section 143(3)Section 154

1. The order passed U/s. 250 of the Act dated 11/01/2024 upholding the Assessing Officer order U/s. 143(3) of the Act dated 30/12/2018, determining the total income at Rs. 47,11,440/- inclusive of disputed capital gains of Rs. 44,12,240/- is erroneous under the given facts and circumstances of the case. 2. The Ld. CIT(A) disposed

VIJAYA DURGA PENUMALA,RAJAHMUNDRY vs. THE INCOME TAX OFFICER, WARD-2(1), , RAJAHMUNDRY

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

ITA 237/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam31 Jul 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.237/Viz/2024 (िनधा"रण वष" / Assessment Year :2016-17)

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(2)Section 143(3)Section 154

1. The order passed U/s. 250 of the Act dated 11/01/2024 upholding the Assessing Officer order U/s. 143(3) of the Act dated 30/12/2018, determining the total income at Rs. 47,11,440/- inclusive of disputed capital gains of Rs. 44,12,240/- is erroneous under the given facts and circumstances of the case. 2. The Ld. CIT(A) disposed

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

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

ITA 25/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

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

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

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

ITA 236/VIZ/2020[2016-17]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2016-17

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 ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

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

ITA 49/VIZ/2021[2015-16]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2015-16

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 ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, , VISAKHAPTNAM

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

ITA 67/VIZ/2021[2016-17]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2016-17

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

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

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

ITA 396/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

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

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

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

ITA 397/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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

ITA 399/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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

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

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

ITA 12/VIZ/2015[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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 VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASST. CIT,, VISAKHAPATNAM

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

ITA 325/VIZ/2017[2012-2013]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2012-2013

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

VISAKHAPATNAM PORT AUTHORITY, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

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

ITA 235/VIZ/2020[2015-16]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2015-16

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

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

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

ITA 26/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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

ANDHRA PAPER LIMITED,RAJAHMUNDRY vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

In the result, appeal of the assessee is dismissed

ITA 349/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2020-21

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.349/Viz/2024 (निर्धारण वर्ा/ Assessment Year:2020-21) Vs. Acit – Circle -1 Andhra Paper Limited 14-6-9, Admin Office Veerabhadrapuram Kateru Road Rajahmundry-533101 Sri Ramnagar S.O. (Rajahmundry) Andhra Pradesh Rajahmundry (Urban) East Godavari – 533105 Andhra Pradesh [Pan: Aaact8849D]

Section 142(1)Section 143(2)Section 143(3)Section 92C

84,681/- claimed as payment towards use of “marketing intangible” by the assessee. 8. A draft order under section 144C(1) of the Act dated 18.09.2023 was issued to the assessee proposing the adjustment as concluded by the TPO. The assessee filed its objection on 17.10.2023 before the Ld. Dispute Resolution Panel-1, Bengaluru [in short “DRP”]. The DRP rejected