INCOME TAX OFFICER, TENALI vs. SURYAPRAKASARAO KANAPARTHY, BETHAPUDI, REPALLE

In the result, the Cross Objection filed by the assessee is allowed in terms of our aforesaid observations, while for the appeal filed by the revenue having been rendered as academic in nature, is ...

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.239/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Income Tax Officer, Vs. Suryaprakasarao Tenali. Kanaparthy, Bethapudi, Repalle, Bapatla. Pan: Dmqpk7509P (Appellant) (Respondent)

46A of the Income Tax Rules, 1962. 3. The Ld. CIT(A), NFAC erred on facts in stating that the appellant is employee of M/s. Sai Marine Exports Private Limited and it is beyond his capacity to make deposits of Rs.1.12 Crores. 4. The Ld.CIT(A) erred in deleting the addition on facts that even the assessee is an employee

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 loss allowed to be carried forward against the income assessed to tax This additional ground raised by the appellant is not in agreement with the provisions of Section 68 r.w.s 1158BE of the Act. The plain reading of the Section 115BBE(2) denies any set off of any loss to be allowed if the addition is in the nature

KOLLI SUBRAHMANYAM,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-2(2), , VIJAYAWADA

In the result, appeal filed by the assessee is dismissed

Bench: Shri Duvvuru R L Reddy, Hon’Ble & Shri S. Balakrishnan, Hon'Ble

section 144 r.w.s. 263 of the Act. In the assessment order, the AO rejected the books of account u/s 145(2) and estimated the contracts business income at 8% of the gross receipts net of depreciation, which resulted in addition of Rs. 25,03,724/-. Further, the AO made addition of Rs. 35,79,539/- towards unexplained increase

DCIT, CIRCLE - 3(1), VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

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

Bench: Shri Ravish Sood & Shri Balakrishnan S.

46A(3) of Income-tax Rules, 1962. Ground 2.2. The Ld. CIT(A) erred in adjudicating that the absence of joint venture between appellant and lessee cannot be sufficient ground to hold that the receipts are not in nature of business receipts. The Ld. CIT(A) also erred in adjudicating that the absence of sharing agreement cannot be sufficient ground

DCIT, CIRCLE -3(1), VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

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

Bench: Shri Ravish Sood & Shri Balakrishnan S.

46A(3) of Income-tax Rules, 1962. Ground 2.2. The Ld. CIT(A) erred in adjudicating that the absence of joint venture between appellant and lessee cannot be sufficient ground to hold that the receipts are not in nature of business receipts. The Ld. CIT(A) also erred in adjudicating that the absence of sharing agreement cannot be sufficient ground

DCIT, CIRCLE - 3(1), , VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

depreciation is allowed. Hence, this ground\nof appeal without prejudice is allowed.\n6.4. Ground of Appeal No. 5– 14A disallowance of Rs 15.42 lacs\nThe Appellant had earned dividend income of Rs. 20,585/- from\ninvestments made in quoted equity shares. Appellant submitted that no\nexpenditure has been incurred for earning the exempt income. AO\nmade an addition

ASST. COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. FYSOLATE TECHNOLOGIES, VIJAYAWADA

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.182/Viz/2023 (िनधा"रण वष" / Assessment Year : 2017-18) Assistant Commissioner Of Vs. Fysolate Technologies, Income Tax, Vijayawada. Vijawayada. Pan: Aacff5633L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Mithilesh Sannareddy ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 16/04/2024 घोषणा क" तारीख/Date Of : 15/07/2024 Pronouncement O R D E R

Depreciation PBDIT (OR-OC) 66,12,34,425 PBDIT / OR (%) 60.44 PBDIT / OC (%) 152.75 5. The Ld. TPO examined the analysis made by the assessee under CUP method and TNMM and observed that as per the 6 OECD Guidelines which defines “Tested Party” should have the following attributes: 1. Available of reliable and accurate data for comparison 2. Least Complex