DEPUTY COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. NS HEALTHCARE SERVICES PRIVATE LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

6. Under the facts and circumstances, the Ld. CIT(A) has erred in upholding only 25% of Rs 5,04,336/-, without appreciating the factthat out of the expenditure claimed by the assessee company at Rs 11,61,792/-, an amount of Rs.5,04,336/- was disallowed holding that it was paid to referral Doctors/RMPs, which is against

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

6. Under the facts and circumstances, the Ld. CIT(A) has erred in upholding only 25% of Rs 5,04,336/-, without appreciating the factthat out of the expenditure claimed by the assessee company at Rs 11,61,792/-, an amount of Rs.5,04,336/- was disallowed holding that it was paid to referral Doctors/RMPs, which is against

DEPUTY COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. NS HEALTHCARE SERVICES PRIVATE LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

6. Under the facts and circumstances, the Ld. CIT(A) has erred in upholding only 25% of Rs 5,04,336/-, without appreciating the factthat out of the expenditure claimed by the assessee company at Rs 11,61,792/-, an amount of Rs.5,04,336/- was disallowed holding that it was paid to referral Doctors/RMPs, which is against

DEPUTY COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. NS HEALTHCARE SERVICES PRIVATE LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

6. Under the facts and circumstances, the Ld. CIT(A) has erred in upholding only 25% of Rs 5,04,336/-, without appreciating the factthat out of the expenditure claimed by the assessee company at Rs 11,61,792/-, an amount of Rs.5,04,336/- was disallowed holding that it was paid to referral Doctors/RMPs, which is against

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

6. Under the facts and circumstances, the Ld. CIT(A) has erred in upholding only 25% of Rs 5,04,336/-, without appreciating the factthat out of the expenditure claimed by the assessee company at Rs 11,61,792/-, an amount of Rs.5,04,336/- was disallowed holding that it was paid to referral Doctors/RMPs, which is against

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

6. Under the facts and circumstances, the Ld. CIT(A) has erred in upholding only 25% of Rs 5,04,336/-, without appreciating the factthat out of the expenditure claimed by the assessee company at Rs 11,61,792/-, an amount of Rs.5,04,336/- was disallowed holding that it was paid to referral Doctors/RMPs, which is against

SRI LAKSHMI VENKATESWARA MUTUALLY AIDED COOPERATIVE SOCIETY LIMITED,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1(1), VISAKHAPATNAM

6,30,267/- on\nthe surplus fund from the Banks and claimed deduction under section\n80P(2)(a)(i) of the Act. Assessee submitted its reply and submitted that the\nclaim is admissible as per section 80P of the Act. Ld. AO on considering the\nprovisions of section 80P(2) of the Act concluded that, this section only\nenvisages interest

DEVI SEA FOODS LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE -3(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.156/Viz/2022 (निर्धारण वर्ा / Assessment Year : 2018-19) M/S Devi Sea Foods Limited Vs. Deputy Commissioner Of 50-1-51/1, A.S.R.Nagar Income Tax Seethammadhara Circle-3(I) Visakhapatnam Visakhapatnam [Pan : Aabcd0248B] अपीलधथी की ओर से/ Appellant By : Shri D.Anand, Ar प्रत्यधथी की ओर से / Respondent By : Shri M.N.Murthy Naik, Cit(Dr) सुिवधई की तधरीख / Date Of Hearing : 01.12.2022 घोर्णध की तधरीख/Date Of Pronouncement : 16.12.2022 O R D E R Per Shri S.Balakrishnan:

disallowance as per Rule 8D of I.T.Rules, 1962. Aggrieved by the order passed by the AO based on the directions of the Ld.DRP, the assessee is in appeal before us and raised the following grounds : 1. The Final Assessment order incorporating Transfer Pricing adjustment passed by the learned Assessing Officer 4 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam

3F INDUSTRIES LIMITED,TADEPALLIGUDEM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU

In the result, appeal filed by the assessee is partly allowed for statistical purposes

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

vii. Kirti Agrotech Limited Ground No.4: Rejecting of entrepreneurial companies: Notwithstanding an objective comparative analysis rejecting entrepreneurial companies engaged in palm tree plantation and production inter alia including: i. Godrej Agrovet Limited (Vegetable Oil Segment). ii. Ruchi Soya Industries Limited (Extractions segment) iii. Navabharat Agro Products Private Limited iv. Oil Palm India Limited Corporate Tax Matters Ground No.5: Disallowing Miscellaneous

BAYYE CHANDRA KUMAR,WEST GODAVARI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

Bench: Us:

disallowed 10% of the assessee's claim for deduction of purchase of metal of Rs. 2,41,97,970/- and worked out a consequential addition of Rs.24,19,797/-. Accordingly, the A.O., vide his order passed under Section 143(3), dated 12.12.2019, framed the assessment in the case of the assessee. 4. Aggrieved, the assessee carried the matter in appeal

DEPUTY COMMISSIONER OF INCOME TAX,(EXEMPTIONS), VIJAYAWADA vs. BHARAT REDDY EDUCATIONAL SOCIETY, , HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other

THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS),, VIJAYAWADA vs. SRI MAHANANDEESWARA EDUCATIONAL SOCIETY, HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other

DEPUTY COMMISSIONER OF INCOME TAX,(EXEMPTIONS), VIJAYAWADA vs. KESAVA REDDY EDUCATIONAL TRUST,, HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other

DEPUTY COMMISSIONER OF INCOME TAX,(EXEMPTIONS), VIJAYAWADA vs. SRI MAHANANDEESWARA EDUCATIONAL SOCEITY, HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other

THE DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTION), VIJAYAWADA vs. SRI SATYANARAYANA SWAMY EDUCATIONAL SOCIETY, HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other

THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), , VIJAYAWADA vs. SRI SARASWATHI EDUCATIONAL SOCIETY,, HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other

THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS),, VIJAYAWADA vs. SRI KESAVA REDDY EDUCATIONAL TRUST,, HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other

DEPUTY COMMISSIONER OF INCOME TAX,(EXEMPTIONS), VIJAYAWADA vs. SRI VENKATESWARA EDUCATIONAL SOCIETY, HYDERABAD

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos.87 & 288/Viz/2018 (निर्धारण वर्ा / Assessment Years: 2013-14 & 2014-15)

section 13(1)(c) of the Act. 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) is completely justified in deleting the adhoc disallowance of expenditure at 10% as such disallowance of expenditure on adhoc basis has no basis. Adhoc disallowance unsupported by reasons and basis is unjustified under law. 5. Any other