JANAKI RAM BABJI RAO ANNAM,VIJAYAWADA vs. INCOME TAX OFFICER, WARD 3(1), VIJAYAWADA

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

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No. 92/Viz/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Janaki Ram Babji Rao Annam, Vs. Income Tax Officer, Vijayawada. Ward-3(1), Pan: Aecpa4464Q Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri C. Subrahmanyam, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 09/10/2024 घोषणा क" तारीख/Date Of : 24/10/2024 Pronouncement O R D E R Per Duvvuru Rl Reddy:

condone the delay of 11 days in 3 filing the appeal of the assessee before the Tribunal and proceed to adjudicate the appeal on merits. 4. Briefly stated the facts of the case are that the assessee is an individual filed his return of income electronically on 09/12/2017 declaring a total income

ACIT,, VIJAYAWADA vs. SRI PRAKASH EDUCATIONAL SOCIETY, TUNI

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

condone the long delay caused by the assessee in applying for the registration. Therefore, the Assessing Officer had no other option but to complete the assessments in the status of AOP also closing his eyes towards Section 11 and Section 13. To that extent, the Assessing Officer was right as he had acted only according to will

ACIT, (EXEMPTIONS), EXEMPTIONS CIRCLE,, VIJAYAWADA vs. SRI PRAKASH EDUCATIONAL SOCIETY,, TUNI,

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

condone the long delay caused by the assessee in applying for the registration. Therefore, the Assessing Officer had no other option but to complete the assessments in the status of AOP also closing his eyes towards Section 11 and Section 13. To that extent, the Assessing Officer was right as he had acted only according to will

ACIT, EXEMPTIONS,, VIJAYAWADA vs. SRI PRAKASHA EDUCATIONAL SOCIETY,, TUNII

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

condone the long delay caused by the assessee in applying for the registration. Therefore, the Assessing Officer had no other option but to complete the assessments in the status of AOP also closing his eyes towards Section 11 and Section 13. To that extent, the Assessing Officer was right as he had acted only according to will

RAJAJI EDUCATIONAL SOCIETY,VISAKHAPATNAM vs. INCOME TAX OFFICER, EXEMPTION WARD, VISAKHAPATNAM

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

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Ble

section 10(23C)(iiiad) of the Act and estimated 45% of the gross receipts as income of the assessee. Page. No 2 ITA Nos. 436 & 437/VIZ/2025 Rajaji Educational Society 4. On being aggrieved by the order of the Ld. AO, assessee filed an appeal before Ld. CIT(A). Assessee did not respond to the multiple opportunities provided

RAJAJI EDUCATIONAL SOCIETY,VISAKHAPATNAM vs. INCOME TAX OFFICER, EXEMPTION WARD, VISAKHAPATNAM

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

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Ble

section 10(23C)(iiiad) of the Act and estimated 45% of the gross receipts as income of the assessee. Page. No 2 ITA Nos. 436 & 437/VIZ/2025 Rajaji Educational Society 4. On being aggrieved by the order of the Ld. AO, assessee filed an appeal before Ld. CIT(A). Assessee did not respond to the multiple opportunities provided

KVC INFRASTRUCTURES,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

The appeal of the assessee is allowed for statistical purposes, in terms of our aforesaid observations

Bench: Us:

Section 145(3) without pointing out any defects in the audited books. 6. Arbitrary Estimation of Income Without Evidence: The AO estimated income at 8% of gross receipts without providing any industry benchmarks or supporting evidence. 7. Additional Ground (General Prayer): The appellant craves leave to add, alter, amend, modify, or withdraw any of the above grounds

HERMON EDUCATIONAL SOCIETY,VISAKHAPATNAM vs. INCOME TAX OFFICER (EXEMPTION WARD), VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed

Bench: Shri G. Manjunatha & Shri K. Narasimha Chary

condone the delay of 45 days in filing the appeal before the Tribunal and admit the appeal for adjudication. 3. Brief facts of the case, are that, the assessee society viz., Hermon Educational Society, Visakhapatnam is running a school by name Hermon School at KRM Colony, Maddilapalem, Visakhapatnam. The assessee society filed it’s return of income for the impugned

THE INCOME TAX OFFICER, WARD-1, , TUNI vs. MK AQUA HATCHERY, THONDANGI(M)

In the result, appeal of the revenue is dismissed

Bench: Shri N.K.Choudhry & Shri D.S. Sunder Singhआयकरअपीलसं./I.T.A.No.436/Viz/2019 (ननधधारण वर्ा/ Assessment Year:2015-16) Income Tax Officer Vs. M/S M.K.Aqua Hatchery Ward-1 D.No.3-36, Chintakayalapeta Tuni Thondangi (M) E.G.Dist. [Pan :Aazfm0955H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Smt.Suman Malik, Dr प्रत्यधथी की ओर से/ Respondent By : Shri G.V.N.Hari, Ar सुनवधई की तधरीख/ Date Of Hearing : 22.12.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Shri D.S.Sunder Singh: This Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) [Cit(A)], Rajamahendravaram In Itano.10128/2017-18/Ito,W-1,Tuni/Vsp/2018-19 Dated 21.03.2019 For The Assessment Year(A.Y.)2015-16 With The Delay Of 17 Days. The Assessing Officer Filed The Condonation Petition Giving Administrative Reasons For Delay. The Ld.Ar Expressed No Objection For Condoning The Delay. Therefore, The Delay Is Condoned & The Appeal Is Admitted.

delay is condoned and the appeal is admitted. 2 I.T.A. No.436/Viz/2019, A.Y.2015-16 M/s M.K.Aqua Hatchery, Thondangi 2. All the grounds in this appeal are related to the addition of Rs.2,12,50,000/- made u/s 68 of the Income Tax Act, 1961 (in short ‘Act’) which was deleted by the CIT(A. During the assessment proceedings, the Assessing officer

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISAKHAPATNAM vs. SRI VIJAYA VISAKHA MILK PRODUCERS COMPANY LIMITED, VISAKHAPATNAM

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

delay is condoned. 3. The Revenue has raised the following grounds of appeal:- “1) On the facts and circumstances of the case ld. CIT(A) erred in deleting the addition of Rs. 22,90,84,000/- made towards additional price/withheld price of milk produced. 2) On the facts and circumstances of the case ld. CIT(A) erred in not appreciating

KOSANAM RAMA RAO,GUNTUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), GUNTUR

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Us:

condone the delay involved in filing of the present appeal. 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 that have been pressed into service by the Ld. AR to drive home his contentions. 11. Before proceeding

OURS YOUTH CLUB,VIZIANAGARAM vs. INCOME TAX OFFICER, WARD-1, VIZIANAGARAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.22/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2017-18) Ours Youth Club Vs. Income Tax Officer 1-19-17, Bc Colony Agraharam Ward-1 Vizianagaram Vijayanagaram [Pan : Aaaao2600H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

condone the delay and admit the appeal for hearing. 2. Brief facts of the case are that the assessee, an Association of Persons, registered as Society is engaged in the business of supply of manpower to the Government Sectors like municipalities, hospitals etc. It receives payments from such organizations for supply of manpower and the society in turn pays

THE ANIGANDLAPADU PACS LTD,KRISHNA DIST vs. INCOME TAX OFFICER, WARD(1)1 VIJAYAWADA, VIJAYAWADA

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.300/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2020-21) The Anigandlapadu Pacs Ltd. Vs. Income Tax Officer 10-1, Anigandlapadu Village Ward-1(1) Penuganchiprolu Post Vijayawada Penuganchiprolu Mandal Krishna Dist. [Pan : Aacat7983Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

condone the delay and admit the appeal for hearing in the interest of justice. 3. Brief facts of the case are that the assessee is a cooperative society, provides credit facilities to it’s members i.e. sanction of crop loans out of deposits collected from it’s members. It also provides services i.e. supply of fertilisers and manures, marketing

SRINIVASA RAO ARNEPALLI,KRISHNA DIST vs. PRINCIPAL COMMISSIONER OF INCOME TAX, VIJAYAWADA

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.153/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2017-18) Srinivasa Rao Arnepalli Vs. Principal Commissioner Of Bhavishya Edible Oil Refinery Income Tax 140/1, Kodurupadu Vijayawada Bapulapadu Mandalam Krishna Dist. [Pan : Aftpa9285K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

condone the delay and admit the appeal for hearing. 2. Brief facts of the case are that the assessee is an individual, in the business of manufacturing edible oil in the name & style of Bhavishya Edible Oil Refinery filed return of income for the A.Y.2017-18 on 3 I.T.A. No.153/Viz/2023, A.Y.2017-18 Sinivasa Rao Arnepalli, Krishna Dist. 30.10.2017, admitting total income

ARIMILLI RAMA KRISHNA,WEST GODAVARI DIST vs. ACIT, CIRCLE-1, RAJAHMUNDRY

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

delayed, there should have been a notice issued under section 143(2) as the requirement to issue notice cannot be dispensed with. Further, the Hon’ble High Court of Delhi in the case of PCIT v. S.G. Portfolio Pvt. Ltd. (2023) 454 ITR 761 (Delhi) had, inter alia, held that where the assessee company had filed the return income

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU vs. SIRIUS OVERSEAS PRIVATE LIMITED, TANUKU

In the result, cross objections of the assessee for the A

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीलसं./I.T.A.No.521 /Viz/2019 To 523/Viz/2019 (निर्धारण वर्ा/Assessment Year:2009-10, 2012-13 & 2013-14) Asst.Commissioner Of Income Tax Vs. M/S Sirius Overseas Private Circle-1 Limited Eluru D.No.2-152, Rice Mill Street Velpur, Tanuku Mandal West Godavari District [Pan : Aafcs5054C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Cross Objection No.142/Viz/2019 To 144/Viz/2019 (Arising Out Of I.T.A. No.521/Viz/2019 To 523/Viz/2019) M/S Sirius Overseas Private Limited Vs. Asst.Commissioner Of D.No.2-152, Rice Mill Street Income Tax Velpur, Tanuku Mandal Circle-1, Eluru West Godavari District [Pan : Aafcs5054C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit(Dr) प्रत्यधथी की ओर से / Respondent By : Shri G.V.N.Hari, Ar सुिवधई की तधरीख / Date Of Hearing : 15.09.2021 घोर्णध कीतधरीख/Dt. Of Pronouncement : 24 .09.2021

delay in filing the cross objections is condoned. These appeals are filed by the revenue against the order of the Commissioner of Income Tax (Appeals) [CIT(A)]-2 Guntur in ITA No.56/GNT/CIT(A)-2/2011-12 dated 29.11.2018, CIT(A)-11, Hyderabad in Appeal No.188/2017-18,ACIT,C-1-Rjy/CIT(A)-11/Hyd and CIT(A)-11, Hyderabad Appeal No.189/2017-18/ACIT

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU vs. SIRIUS OVERSEAS PRIVATE LIMITED, TANUKU

In the result, cross objections of the assessee for the A

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीलसं./I.T.A.No.521 /Viz/2019 To 523/Viz/2019 (निर्धारण वर्ा/Assessment Year:2009-10, 2012-13 & 2013-14) Asst.Commissioner Of Income Tax Vs. M/S Sirius Overseas Private Circle-1 Limited Eluru D.No.2-152, Rice Mill Street Velpur, Tanuku Mandal West Godavari District [Pan : Aafcs5054C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Cross Objection No.142/Viz/2019 To 144/Viz/2019 (Arising Out Of I.T.A. No.521/Viz/2019 To 523/Viz/2019) M/S Sirius Overseas Private Limited Vs. Asst.Commissioner Of D.No.2-152, Rice Mill Street Income Tax Velpur, Tanuku Mandal Circle-1, Eluru West Godavari District [Pan : Aafcs5054C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit(Dr) प्रत्यधथी की ओर से / Respondent By : Shri G.V.N.Hari, Ar सुिवधई की तधरीख / Date Of Hearing : 15.09.2021 घोर्णध कीतधरीख/Dt. Of Pronouncement : 24 .09.2021

delay in filing the cross objections is condoned. These appeals are filed by the revenue against the order of the Commissioner of Income Tax (Appeals) [CIT(A)]-2 Guntur in ITA No.56/GNT/CIT(A)-2/2011-12 dated 29.11.2018, CIT(A)-11, Hyderabad in Appeal No.188/2017-18,ACIT,C-1-Rjy/CIT(A)-11/Hyd and CIT(A)-11, Hyderabad Appeal No.189/2017-18/ACIT

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, GUTNUR vs. ARUNACHALAM MANICKVEL,, GUTNUR

In the result, appeal of the revenue for the A

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhआयकर अपीलसं./I.T.A.No.202/Viz/2020 To 207/Viz/2020 (ननधधारण वर्ा/Assessment Year:2011-12 To 2016-17) Dy.Commissioner Of Vs. Sri Arunachalam Manickavel Income Tax Prop : M/S Bharathi Soap Works Central Circle-1 11/25, Amaravathi Road Guntur Gorantla, Guntur [Pan :Acfpa3107K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit Dr प्रत्यधथी की ओर से / Respondent By : Shri M.V.Prasad, Ar. सुनवधई की तधरीख / Date Of Hearing : 25.11.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Bench :

condone the delay and admit the appeals of the revenue. 2. The Revenue has raised the following grounds which are common for all the assessment years. 1. The order of the Ld.CIT(A) is erroneous both on the facts and in law. 2. The Ld. CIT (Appeals) ought to have appreciated the probative value of voluntary admission u/s.132