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

13. In the above background, the key question in the present case is whether the disallowance of the expenditure will be made even where the investment has not resulted in any exempt income during the AY in question but where potential exists for exempt income being earned in later AYs. 14. In the Explanatory Memorandum to the Finance

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

13. In the above background, the key question in the present case is whether the disallowance of the expenditure will be made even where the investment has not resulted in any exempt income during the AY in question but where potential exists for exempt income being earned in later AYs. 14. In the Explanatory Memorandum to the Finance

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

13. In the above background, the key question in the present case is whether the disallowance of the expenditure will be made even where the investment has not resulted in any exempt income during the AY in question but where potential exists for exempt income being earned in later AYs. 14. In the Explanatory Memorandum to the Finance

INCOMETAX OFFICER, WARD-3(1), VISAKHAPATNAM vs. SURENDRA NATH GUBBALA, VISAKHAPATNAM

Bench: Us:

section 48(i) of the Act and deleted the disallowance made by the A.O. For the sake of clarity, we deem it apposite to cull out the observations of the CIT(A), as under: “5. Findings & Decision: 5.1 I have gone through the Assessment Order, Statement of Facts and Grounds of Appeal filed by the appellant and the written submissions

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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

section 40A(3) of the Act wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), VIJAYAWADA vs. KANDULA LAKSHUMMA MEMORIAL EDUCATIONAL SOCIETY, KADAPA

In the result, appeal of the revenue as well as the cross objections of the assessee are dismissed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.179/Viz/2018 (निर्धारण वर्ा/Assessment Year:2013-14) Deputy Commissioner Of Vs. M/S Smt.Kandula Income Tax (Exemptions) Lakshumma Memorial Vijayawada Educational Society D.No.3/429 Raja Reddy Street Kadapa [Pan :Aadas4432Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Cross Objection No.91/Viz/2018 (Arising Out Of I.T.A. No.179/Viz/2018) (निर्धारण वर्ा/Assessment Year:2013-14) Vs. M/S Smt.Kandula Lakshumma Deputy Commissioner Of Memorial Educational Society Income Tax (Exemptions) D.No.3/429 Vijayawada Raja Reddy Street Kadapa [Pan :Aadas4432Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) रधजस्व की ओर से /Revenue By : Shri B.Rama Krishna, Dr निर्धाऩरती की ओ रसे / Assessee By : Shri G.V.N.Hari, Ar सुिवधई की तधरीख / Date Of Hearing : 18.08.2020 घोर्णध की तधरीख/Date Of Pronouncement : 21.09.2020

disallowed to the extent of 10% amounting to Rs.11,05,053/-. 5 I.T.A. No.179/Viz/2018 and CO No.91/Viz/2018, A.Y.2013-14 M/s Smt. Kandula Lakshumma Memorial Educational Society, Kadapa 3. Against the order of the AO, the assessee went on appeal before the CIT(A) and the Ld.CIT(A) found from the details furnished by the assessee that there was no violation

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:

9. Per contra, Dr. Aparna Villuri, the Learned Senior Departmental Representative (for short, “Ld. Sr. DR”), relied upon the orders of the lower authorities. 10. We have given thoughtful consideration to the contentions of the Learned Authorized Representatives of both parties in the backdrop of the orders of the authorities below and the material available on record. 11. Ostensibly

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.

section 14A. However relying on various decision of Hon’ble courts relied by appellant in its submission the disallowance is restricted to Rs 20,585/-. The balance disallowance is deleted. 6.5. Ground of Appeal No. 6– disallowance u/s 43B Appellant submitted that provision of gratuity and leave encashment has been disallowed in the computation of income. However, Rs 20 lacs

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.

section 14A. However relying on various decision of Hon’ble courts relied by appellant in its submission the disallowance is restricted to Rs 20,585/-. The balance disallowance is deleted. 6.5. Ground of Appeal No. 6– disallowance u/s 43B Appellant submitted that provision of gratuity and leave encashment has been disallowed in the computation of income. However, Rs 20 lacs

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 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