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

12 of the Act. These are tied up grants where the appellant acts as a custodian of the funds given by the funding agency to channelize the same in a particular direction. In case of voluntary contribution, the appellant is free to use the money as per its will and neither have to render the account of the same

SRI KANAKA MAHALAKSHMI AMMAVARI TEMPLE,BURUJUPETA vs. CPC, BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.358/Viz/2024 (िनधा"रण वष"/ Assessment Year: 2015-16) Sri Kanaka Mahalakshmi Ammavari Temple V. Centralized Processing Center D.No. 22-71-26/B, Skml Temple Bangalore. Kotha Road, Burujupeta Visakhapatnam – 530001, Andhra Pradesh [Pan: Aaajs1861M] (अपीलाथ"/ Appellant) (""थ"/ Respondent)

disallowing the capital receipts amounting to Rs.7,09,44,112/- stating that there is a mistake apparent from the record while passing the giving effect order to the Ld. CIT(A) dated 26.06.2024. Page No. 2 I.T.A.No.358/VIZ/2024 Sri Kanaka Mahalakshmi Ammavari Temple 3. Aggrieved by the order of the Ld. CIT(A), assessee is in appeal before

DY CIT, VISAKHAPATNAM vs. KOTU SARATH KUMAR`, VISAKHAPATNAM

In the result, appeals filed by the assessees in ITA Nos

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

disallowed under section 57(iii) of the Act for diverting of funds for non-business purposes. 12. On appeal, ld. CIT(A) deleted

KOTU SARAT KUMAR,VISAKHAPATNAM vs. DY.CIT., VISAKHAPATNAM

In the result, appeals filed by the assessees in ITA Nos

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

disallowed under section 57(iii) of the Act for diverting of funds for non-business purposes. 12. On appeal, ld. CIT(A) deleted

KOTU ANASUYA (LATE),VISAKHAPATNAM vs. DCIT, VISAKHAPATNAM

In the result, appeals filed by the assessees in ITA Nos

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

disallowed under section 57(iii) of the Act for diverting of funds for non-business purposes. 12. On appeal, ld. CIT(A) deleted

GMEDAPADU PACS,EAST GODAVARI vs. ITO, WARD-1, KAKINADA

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.573/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Gmedapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Kss Sarma, Ca रधजस् व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 16/10/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 18/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 10/02/2021 For Ay 2018-19. The Assessee Society Has Assailed The Impugned Order Passed By The Ao On The Following Grounds Of Appeal:

12. Admittedly, it is a matter of fact borne from the record that there is no whisper in the assessment order about the disallowance of the assessee’s claim for deduction under section

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

NS HEALTHCARE SERVICES PRIVATE LIMITED,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VIJAYAWADA

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

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

12. With respect to Ground No. 5 wherein the profit of Rs.9,56,486/- was added to the total income of the assessee, Ld.AR did not argue on this ground and hence dismissed as not pressed. 13. With respect to Ground No. 6 wherein the Ld. AO estimated the disallowance @25% of the expenditure claimed under patient refund account, Ld.AR

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), GUNTUR vs. NSL TEXTILES LIMITED, HYDERABAD

In the result, appeal filed by the Revenue as well as cross objection filed by the assessee is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleacit, Circle-2(1), Vs. M/S. Nsl Textiles Ltd., Nsl Icon, 4Th Floor, D.No. Guntur. 8-2-684/2/A, Banjara Hills, Road No. 12, Hyderabad. Pan No. Aabcj 1299 A (Appellant) (Respondent)

disallowance u/s 14A of the Act was called for in case of no exempt income earned by the assessee, in the relevant assessment year. For the sake of clarity and convenience, we extract relevant part of the order of the Hon’ble High Court of Delhi which reads as under : ―12. Section

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), , VISAKHAPATNAM vs. VISAKHAPATNAM CO-OPERATIVE BANK LIMITED, VISAKHAPATNAM

In the result, appeals filed by the assessee and Revenue are dismissed

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

section 14A, such claim of amortized loss by the assessee-bank needs to be disallowed. Accordingly, the claim of the assessee amounting to Rs. 53,16,693/- was disallowed. 8. On appeal, ld. CIT(A) by following the decision of the coordinate bench of the Visakhapatnam tribunal in assessee’s own case for the Assessment Years

THE VISAKHAPATNAM CO-OPERATIVE BANK LIMITED,,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), VISAKHAPATNAM

In the result, appeals filed by the assessee and Revenue are dismissed

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

section 14A, such claim of amortized loss by the assessee-bank needs to be disallowed. Accordingly, the claim of the assessee amounting to Rs. 53,16,693/- was disallowed. 8. On appeal, ld. CIT(A) by following the decision of the coordinate bench of the Visakhapatnam tribunal in assessee’s own case for the Assessment Years

THE VISAKHAPATNAM CO-OPERATIVE BANK LIMITED, ,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), VISAKHAPATNAM

In the result, appeals filed by the assessee and Revenue are dismissed

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

section 14A, such claim of amortized loss by the assessee-bank needs to be disallowed. Accordingly, the claim of the assessee amounting to Rs. 53,16,693/- was disallowed. 8. On appeal, ld. CIT(A) by following the decision of the coordinate bench of the Visakhapatnam tribunal in assessee’s own case for the Assessment Years