NANDIGAM VEERABRAHMAM,RAJAHMUNDRY vs. INCOME TAX OFFICER, WARD-2(1), RAJAHMUNDRY

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

Bench: Us:

deposits in current Account No.0446100270000177 and 044630100058411 held with Andhra Bank: Rs.17,63,437/-. The A.O. observed that as the assessee had not filed his return of income for the subject year, thus issued notice u/s 148A(b) of the Act, dated 22.03.2022. Thereafter, the A.O. passed an order u/s 148A(d) of the Act, dated 03.04.2022, and issued

MARISETTI DHANA TATAJI,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

cash deposits of Rs.1,72,900 in the same\nbank account.\n4.\nAny other ground that may be urged at the time of appeal\nhearing.\"\n8. Further, assessee has raised following additional legal ground: -\n\"1.\nThe notice dt. 04.04.2022 issued u/s 148 of the Act is invalid as the\nsame was issued

MARISETTI DHANA TATAJI,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

cash deposits of Rs.1,72,900 in the same\nbank account.\n4. Any other ground that may be urged at the time of appeal\nhearing.\"\n8. Further, assessee has raised following additional legal ground: -\n\"1. The notice dt. 04.04.2022 issued u/s 148 of the Act is invalid as the\nsame was issued

MALIPEDDI GIRIDHAR,AMALAPURAM vs. THE ASSTISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, KAKINADA

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.169/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Malipeddi Giridhar V. The Asst. Cit- Circle-1 Income Tax Office D.No.7-1-20, Mgr Mall Deepthi Towers Tk Street, High School Road Main Road, Kakinada - 533001 East Godavari District – 533201 Andhra Pradesh Andhra Pradesh [Pan: Amhpm0210B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Ar राजस्व का प्रतततितित्व/ Department Represented By : Dr. Satyasai Rath, Sr.Ar

Cash deposits of Rs 45,57,000/- 3. Further, Assessing Officer also disallowed Rs 10,54,065/- under section 40(a)(ia) of the Act, depreciation

AMRUTHAVARSHINI DAIRY FARMS PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(4) HYDERABAD, HYDERABAD

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

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

depreciation @ 2.5% of the total turnover which worked out to Rs. 56,53,121/- and added the same to the total income of the assessee. Further, the Ld. AO by observing that the assessee deposited cash

MARISETTI DHANA TATAJI,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

cash deposits of Rs.1,72,900 in the same\nbank account.\n4. Any other ground that may be urged at the time of appeal\nhearing.\"\n8. Further, assessee has raised following additional legal ground: -\n"1. The notice dt. 04.04.2022 issued u/s 148 of the Act is invalid as the\nsame was issued

RANAR AGROCHEM LIMITED,PARAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

depreciation of Rs.6,63,63,807/-against the addition under Sec.68 r.w.s. 115BBE(2) of the Act may be allowed in the interest of equity the assessed income of Rs.3,47,97,000/- which also included and justice and also to be in conformity with enacted law and also judge made law. 6. In the facts and circumstances

UPPALAPADU PRIMARY AGRICULTURAL COOPERATIVE SOCIETY LIMITED,UPPALAPADU, GUNTUR vs. INCOME TAX OFFICER, WARD-2(1), GUNTUR

Bench: Shri Ravish Sood & Shri Balakrishnan Sआ.अपी.सं /Ita No.523/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Uppalapadu Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-2(1), Society Limited, Guntur. Uppalapadu, Guntur. Pan: Aaaau4669G (Appellant) (Respondent) िनधा"रती Shri R. Siva Rama Krishna, "ारा/Assessee By: Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 29/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Society Is Directed Against The Assessment Order Dated 25.01.2024 Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Read With Sections 144 & 144B Of The Income-Tax Act, 1961 (For Short, “The Act”) Dated 25.01.2024 For The Assessment Year 2018-19. The 2 Uppalapadu Primary Agricultural Cooperative Society Limited Vs. Ito

cash deposits of Rs. 77,59,670/- in its bank account with Guntur District Co-operative Bank during the subject year but had not filed its return of income, issued notice under section 148A of the Act. Thereafter, an order under section 148A(d) was passed, followed by a notice issued under section 148 of the Act, dated

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

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.455/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) No. 368 Kolakaluru Vs. The Income Tax Officer, Primary Agricultural Co- Ward-1, Operative Credit Society Tenali. Limited, Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/10/2025 घोषणा की तारीख/Date Of 10/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee-Society Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 25/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The 2 No. 368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs. Ito

deposits in its bank account. In reply, it was submitted by the assessee-society that it was a Primary Agricultural 4 No. 368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs. ITO Cooperative Credit Society (PACCS) registered under The Andhra Pradesh State Co-operative Societies Act, 1963 (APCS Act) and was engaged in the business of providing credit facilities

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

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income

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)

cash flow issues is providing the contribution to Pension Fund over a number of years subject to availability of funds. The case law relied by the Ld. AR in GlaxoSmithkline Pharmaceuticals (supra), the Hon’ble High Court of Bombay Held as follows: “3. Similar issue had been raised by the Revenue in the matter of Commissioner of Income