THE GUNDUGOLANU LARGE SIZE COOPERATIVE SOCIETY LIMITED ,GUNDUGOLANU vs. NFAC, DELHI

sections": [ "143(3)", "143(3A)", "143(3B)", "142(1)", "143(2)", "80P(2)(a)(i)", "80P(2)(d)" ], "issues": "Disallowance

PANDALAPAKA PRIMARY AGRICULTURAL CO-OP SOCIETY LTD,EAST GODAVARI vs. INCOME-TAX OFFICER, WARD-1, KAKINADA

143(3) r.w.s. 144B dated 13.09.2022 by\ndisallowing adding Rs.16,15,079/- being deduction claimed under section\n80P towards income derived from investments under section80P(2)(d)\nbeing a co-operative society.\n\n3.\nThat the ld. CIT(A) confirmed the disallowance

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:

143(3) on 10.02.2021 and mentioned in the body of the order that no addition was made based on the material available on record. However, in the computation sheet attached to the order, the AO disallowed the entire deduction claimed under section 80P, resulting in a tax demand of Rs. 2019107. The appellant challenged this, alleging inconsistency between the assessment

THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. NALLAMILLI SRIDEVI,, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. NALLAMILLI SRIDEVI,, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. VITTALAM NATARAJ PRASAD, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

THE ASSISTANT COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. VITTALAM NATARAJ PRASAD, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.574/Viz/2025 ("नधा"रण वष"/Assessment Year: 2020-21) G Medapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri Kss Sarma, Ca राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 16/10/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

2)(d) of the Act. Accordingly, the AO declined the assessee’s claim for deduction under Section 80P of the Act of Rs. 1,34,79,069/- and vide his order passed under Section 143(3) r.w.s. 144B of the Act, dated 08.09.2022, determined its income at Rs. 1,92,46,882/-. 5. Aggrieved, the assessee society carried the matter

TBR INFRA PVT LTD,ALAMPURAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

In the result, appeal of the assessee is allowed

disallowance of 50% of business promotion expenses\nofRs.46,10,888 claimed by the appellant.\n5. Any other ground that may be urged at the time of appeal\nhearing.\"\n5. Ground Nos. 1 & 5 are general in nature and needs no adjudication.\n6. Ground No.2 challenges the jurisdiction of the Ld. AO for issuance of\nnotice under section 143(2

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA vs. THE KRISHNA DISTRICT MILK PRODUCERS MUTUALLY AIDED CO OP UNION LIMITED, VIJAYAWADA

disallowing deductions under Section 80P(2)(d) for interest income, and treating a difference in payments to GCMMFL as unexplained expenditure. The CIT(A) allowed the assessee's appeal.", "held": "The Tribunal held that the assessee had adequately explained the cash deposits arising from credit sales, and the difference in payment to GCMMFL was due to a wrongly recorded

INCOME TAX OFFICER, BHIMAVARAM vs. THE YENDAGANDHI LARGE SIZE COOPERATIVE SOCIETY LIMITED, YEDAGANDI

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.354/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) Income Tax Officer - Ward - 1 V. The Yendagandhi Large Size Cooperative Society Limited Opp. Ganesh Canteen 4-16, Kk Road, Yendagandhi J.P. Road, Bhimavaram – 534202 West Godavari District – 534186 Andhra Pradesh Andhra Pradesh [Pan: Aacat0967G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

143(2) and 142(1) of the Act were issued and served on the assessee, calling for Page No. 2 I.T.A.No.354/VIZ/2024 C.O. No. 14/VIZ/2024 The Yendagandhi Large Size Cooperative Society Limited information. During the course of assessment proceedings, Ld. Assessing Officer [hereinafter in short “Ld. AO"] noticed that assessee had earned interest and dividend from Eluru District Central

NO H 1043 BHUJABALAPATNAM PRIMARY AGRICULTURE COOPERATIVE CREDIT SOCIETY LTD,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-1, GUDIWADA

In the result, the appeal filed by the assessee is allowed

Bench: The Tribunal. The Petitioner/Appellant Society Has Filed An Affidavit Explaining The Reasons For The Delay In Filing The Appeal Before The Tribunal, Wherein It Was Submitted That The Order Passed By The Ld. Cit(A) Was Sent To The Email Of Its Then Ar, Ca B.V. Rao, Instead Of Its Email "Krishnapacs085@Gmail.Com," As Had Been Requested By It. The Appellant Society Came To Know Of The Order Only When Itd Officials Called Upon It To Pay The Tax Arrears. It Further Submitted That, Due To The Above Circumstances Beyond Its Control & Prayed That The Delay Of 69 Days In Filing The Appeal Before The Tribunal May Please Be Condoned In The Interest Of Justice & That The Appeal Be Decided On Merits.

disallowance of deduction under Section 80P(2)(a)(i), even though the assessee has claimed the said deduction in the return of income filed on 15-12-2019, although belatedly, before the A.O. had completed the assessment under Section 143

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)

2. The Ld. CIT is not justified in invoking the provisions of section 263 of the Act in as much as the order of the Assessing Officer U/s. 143(3) of the Act is neither erroneous nor prejudicial to the interests of the Revenue. 3. The Ld. CIT is not justified in directing the Assessing Officer to consider for disallowance

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)

2. The Ld. CIT is not justified in invoking the provisions of section 263 of the Act in as much as the order of the Assessing Officer U/s. 143(3) of the Act is neither erroneous nor prejudicial to the interests of the Revenue. 3. The Ld. CIT is not justified in directing the Assessing Officer to consider for disallowance

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)

2. The Ld. CIT is not justified in invoking the provisions of section 263 of the Act in as much as the order of the Assessing Officer U/s. 143(3) of the Act is neither erroneous nor prejudicial to the interests of the Revenue. 3. The Ld. CIT is not justified in directing the Assessing Officer to consider for disallowance

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)

2. The Ld. CIT is not justified in invoking the provisions of section 263 of the Act in as much as the order of the Assessing Officer U/s. 143(3) of the Act is neither erroneous nor prejudicial to the interests of the Revenue. 3. The Ld. CIT is not justified in directing the Assessing Officer to consider for disallowance

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)

2. The Ld. CIT is not justified in invoking the provisions of section 263 of the Act in as much as the order of the Assessing Officer U/s. 143(3) of the Act is neither erroneous nor prejudicial to the interests of the Revenue. 3. The Ld. CIT is not justified in directing the Assessing Officer to consider for disallowance

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)

2. The Ld. CIT is not justified in invoking the provisions of section 263 of the Act in as much as the order of the Assessing Officer U/s. 143(3) of the Act is neither erroneous nor prejudicial to the interests of the Revenue. 3. The Ld. CIT is not justified in directing the Assessing Officer to consider for disallowance