DEPUTY COMMSSIONER OF INCOME TAX, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, VISAKHAPATNAM

In the result, appeal filed by the revenue is dismissed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.100/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) Visakhapatnamportauthority Vs. Theasst.Cit -Circle-1(1) Administrative Office Building 4 Th Floor, Prathyakshkar Bhavan Port Area, Visakhapatnam 530001 Mvp Road, Beside Post Office Andhra Pradesh-530001. Sector-8, Mvp Colony Visakhapatnam – 530017 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.103/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) The Dy.Cit Vs. Visakhapatnamportauthority Room No. 412, 4 Th Floor Administrative Office Building Prathyakshkar Bhavan Port Area, Visakhapatnam 530035 Mvp Double Road Andhra Pradesh Opp. Rythubazar Visakhapatnam – 530014 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

depreciation on Railway Permanent Way @ 15% as against 10% restricted in the assessment order, ignoring the section 43(3) of the Income-tax Act, 1961. 7. The appellant craves leave to add or delete or amend or substitute any ground of appeal before and/or at the time of hearing of appeal. 8. For these and other grounds that

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

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)

depreciation in respect of capital dredging is dismissed. 84. Ground No.4 is with respect to disallowance of provision made towards interest payable on Government Loans for Rs. 7 Crs. Before us, on this issue the Ld. AR argued that interest is payable by the assessee on the loans obtained from Government of India and hence the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

80P; (e) “deposit taking non-banking financial company” means a non-banking financial company which is accepting or holding public deposits and is registered with the Reserve Bank of India under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934); Following clause (e) shall be substituted for the existing clause (e) of Explanation 4 to section

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

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

80P; (e) “deposit taking non-banking financial company” means a non-banking financial company which is accepting or holding public deposits and is registered with the Reserve Bank of India under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934); Following clause (e) shall be substituted for the existing clause (e) of Explanation 4 to section

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. M/S. VISAKHAPATNAM PORT AUTHORITY, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

80P; (e) “deposit taking non-banking financial company” means a non-banking financial company which is accepting or holding public deposits and is registered with the Reserve Bank of India under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934); Following clause (e) shall be substituted for the existing clause (e) of Explanation 4 to section

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

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

80P; (e) “deposit taking non-banking financial company” means a non-banking financial company which is accepting or holding public deposits and is registered with the Reserve Bank of India under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934); Following clause (e) shall be substituted for the existing clause (e) of Explanation 4 to section

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

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

80P; (e) “deposit taking non-banking financial company” means a non-banking financial company which is accepting or holding public deposits and is registered with the Reserve Bank of India under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934); Following clause (e) shall be substituted for the existing clause (e) of Explanation 4 to section

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

80P; (e) “deposit taking non-banking financial company” means a non-banking financial company which is accepting or holding public deposits and is registered with the Reserve Bank of India under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934); Following clause (e) shall be substituted for the existing clause (e) of Explanation 4 to section

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

80P of the Act, and treated its profit of Rs. 15,17,083/- as its business income and made an addition of the same. 4 Uppalapadu Primary Agricultural Cooperative Society Limited vs. ITO 4. Aggrieved, the assessee society assailed the assessment order before the CIT(A) but without success. 5. The assessee society aggrieved with the CIT(A) order