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

144 of Income Tax Act, 1961 (in short ‘Act') dated 30.01.2024.\n\n4. Brief facts of the case are that, assessee has failed to furnish return of\nincome for the A.Y. 2018-19. According to the information, Ld. Assessing\nOfficer [hereinafter in short “Ld. AO\"] noticed that the assessee received a\ncommission of Rs. 58,07,237/- during the impugned

POTHINA SATYANARAYANA,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-2(5), VISAKHAPATNAM

In the result, appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.568/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Pothina Satyanarayana, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahdpp1312N Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 19/11/2025 Hearing: घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 10/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 12/02/2024 For The Assessment Year 2018-19. The 2 Pothina Satyanarayana Vs. Ito

Section 147 r.w.s 144 r.w.s 144B of the Income-tax Act, 1961 (for short, “Act”), dated 12/02/2024 for the Assessment Year 2018-19. The 2 Pothina Satyanarayana vs. ITO assessee has assailed the impugned order on the following grounds of appeal before us: 1. “The order of Learned Commissioner of Income Tax (Appeals) is contrary to the facts and also

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

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.437 & 438/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19 & 2020-21) Pandalapaka Primary Agricultural V. Income Tax Officer – Ward – 1 Income Tax Office Co-Op Credit Society Ltd., 3Rd Floor, Deepthi Towers 5-28/1, Pandalapaka Main Road, Kakinada – 533001 Biccavole Mandal – 533345 Andhra Pradesh [Pan: Aabap2382G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

144 of Income Tax Act, 1961 (in short ‘Act’) dated 30.01.2024. 4. Brief facts of the case are that, assessee has failed to furnish return of income for the A.Y. 2018-19. According to the information, Ld. Assessing Officer [hereinafter in short “Ld. AO"] noticed that the assessee received a commission of Rs. 58,07,237/- during the impugned assessment

VAKA GHANTA NAGESWARARAO,GUNTUR vs. INCOME TAX OFFICER, WARD - 1, TENALI

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.251/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Vs. Income Tax Officer-Ward – 1 Vaka Ghanta Nageswararao 4-82-A, Gullapalli Tenali -522201 Goudapalem, Cherukapalli Mandal Andhra Pradesh Guntur – 522309 Andhra Pradesh [Pan:Afjpn4315H] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Malladi Muralidhar, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr. Ar

144 of Income Tax Act, 1961 (in short ‘Act’) dated 08.12.2023. 2. Briefly stated facts of the case are that, assessee being an individual has not filed his return of income for the A.Y. 2015-16. Based on the information available with the Department it was noticed that assessee has made cash deposits of Rs.80,01,000/- and time deposits

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.455/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) No. 368 Kolakaluru Vs. The Income Tax Officer, Primary Agricultural Co- Ward-1, Operative Credit Society Tenali. Limited, Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/10/2025 घोषणा की तारीख/Date Of 10/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee-Society Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 25/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The 2 No. 368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs. Ito

disallowance of deduction U/s. 80P of the Act. 4. Any other ground that may be urged at the time of appeal hearing.” 3. Also, the assessee-society has raised the following additional grounds of appeal: “1. The notice U/s. 148A(b) issued on 21/03/2022 did not provide for clear 7 days of time to the appellant and hence the same

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED, VISAKHAPTNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

b. M/s. Sai Industrial Minerals and Chemicals : Rs.40,06,012/- c. M/s. Techcel Electronics & Services : Rs.9,30,000/- 18. Based on the statements recorded from the Managing Director during the survey operations, Assessing Officer made a disallowance amounting to Rs.91,79,472/- considering it as payment to bogus sub-contractors and also made an addition of Rs. 1

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED, VISAKHAPTNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

b. M/s. Sai Industrial Minerals and Chemicals : Rs.40,06,012/- c. M/s. Techcel Electronics & Services : Rs.9,30,000/- 18. Based on the statements recorded from the Managing Director during the survey operations, Assessing Officer made a disallowance amounting to Rs.91,79,472/- considering it as payment to bogus sub-contractors and also made an addition of Rs. 1

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), , VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED,, VISAKHAPATNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

b. M/s. Sai Industrial Minerals and Chemicals : Rs.40,06,012/- c. M/s. Techcel Electronics & Services : Rs.9,30,000/- 18. Based on the statements recorded from the Managing Director during the survey operations, Assessing Officer made a disallowance amounting to Rs.91,79,472/- considering it as payment to bogus sub-contractors and also made an addition of Rs. 1

SRI TIRUMALA ESTATES AND FARMLANDS,VISAKHAPATNAM vs. ACIT, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowance of rent paid under Section 40(a)(ia) of the Act, for non-deduction of TDS, and additions towards difference in net profit declared for the assessment year 2015-16 and assessment year 2017-18 for Rs.4,23,755/-. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A), and such appeal

SRI TIRUMALA ESTATES AND FARMLANDS,VISAKHAPATNAM vs. ACIT, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowance of rent paid under Section 40(a)(ia) of the Act, for non-deduction of TDS, and additions towards difference in net profit declared for the assessment year 2015-16 and assessment year 2017-18 for Rs.4,23,755/-. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A), and such appeal

SREE SHANTINATH MUNISUVARAT SWAMY RAJENDRA SURI JAIN TRUST,TANUKU vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), HYDERABAD, TANUKU

disallowed the claim of the appellant\nin accordance with the provisions of Section 80A(5) of the Act. It is further\nsubmitted that in accordance with the provisions of Section 80A(5) of the\nAct, where the assessee fails to make a claim in his return of income for\nany deduction under section 10A or section 10AA or section

KOSANAM RAMA RAO,GUNTUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), GUNTUR

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Us:

disallowance of the assessee’s claim for deduction of delayed deposit of the employees’ share of contribution towards Provident Fund: Rs. 16,382/-. 4. Thereafter, the Addl/Joint Commissioner of Income Tax, NFAC, observed that the assessee had during the subject year sold certain properties for a consideration of Rs. 72.75 lacs. It was observed by him that

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. VIZAG RE-BARS PRIVATE LIMITED, VISAKHAPATNAM

In the result, the cross objection filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

section 147 r.w.s. 144 of Income Tax Act, 1961 (in short ‘Act’) dated 23.05.2023. Cross objection is filed by the assessee. 2. Brief facts of the case are that, assessee is a Private Limited Company, engaged in trading in Iron & Steel and filed its return of income for the A.Y.2017-18 on 14.10.2017 admitting Nil income and claiming current year loss

THE MACHILIPATNAM POSTAL DEPTL & GDS CO-OP CREDIT SOCIETY LIMITED NO H164,MACHILIPATNAM vs. INCOME TAX OFFICER, WARD-1, MACHILIPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.249/Viz/2025 (निर्धारणवर्ा/ Assessment Year: 2017-18) The Machilipatnam Postal Deptl & Gds V. Income Tax Officer – Ward -1 Co-Op Credit Society Limited No. H164 Aayakar Bhavan, Parasupeta Machilipatnam – 521001 Machilipatnam – 521001 Andhra Pradesh Andhra Pradesh [Pan: Aafat5514L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

144 of the Act. Ld. AO during the scrutiny proceedings, issued notice under section 142(1) of the Act calling for information regarding the bank account statement and details of Specified Bank Notes (in short “SBN) deposited by the assessee into the accounts. Assessee produced books of accounts physically before the Ld. AO. Assessee also filed physical copy

DASARI SAI ANNAPURNA L/R OF LATE DASARI GOPI KRISHNA REDDY,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), VIJAYAWADA, VIJAYAWADA

In the result, the appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.583/Viz/2025 (िनधा"रण वष"/Assessment Year:2015-16) Dasari Sai Annapurna Vs. Assistant Commissioner L/R Of Late Dasari Gopi Of Income Tax, Krishna Reddy, Central Circle-2(1), Vijayawada. Vijayawada. Pan: Aeipd0990C (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Mv Prasad, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 27/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 28/03/2022, For The Assessment Year 2015-16. The 2 Dasai Sai Annapurna L/R Of Late Dasari Gopi Krishna Reddy Vs. Acit

disallowing the claim of exemption u/s.54F totally would have considered exemption on one flat u/s.54F of the I.T. Act. 3 Dasai Sai Annapurna L/R of Late Dasari Gopi Krishna Reddy vs. ACIT 8. The Appellant craves leave to add, amend, alter, vary and/or withdraw any or all the above grounds of appeal.” 2. Succinctly stated, the assessee had filed

SEELAMSETTY BALAJI,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-2(1), VIJAYAWADA

In the result, appeal of the assessee is allowed

disallowance of indexed cost of improvement.\n3.\nAny other grounds may be urged at the time of hearing.\"\n6. Assessee also filed a petition seeking admission of additional ground as\nfollows: -.\n\"The notice dt. 11.03.2024 issued u/s 148 of the Act is invalid as the same\nwas issued by the JAO but not the FAO, in contravention

SATYAVATHI GOLKONDA,MACHILIPATNAM vs. INCOME TAX OFFICER, WARD-1, MACHILIPATNAM

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated hereinabove

Bench: Shri Duvvuru Rl Reddy, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./ I.T.A. No. 219/Viz/2024 (िनधा"रण वष" / Assessment Year : 2016-17) Satyavathi Golkonda, Vs. Income Tax Officer, Ward-1, Mig-102, Old Aphb Colony, Aayakar Bhavan, Paraspet, Machilipatnam, Krishna District, Machilipatnam, Andhra Pradesh – 521001. Andhra Pradesh-521001. Pan: Attpg1361J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri K. Siva Ram Kumar, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 07/08/2024 घोषणा क" तारीख/Date Of : 08/08/2024 Pronouncement O R D E R

section 144(1)(b) of the Act and proceeded to complete the assessment as best judgment assessment. During the assessment proceedings, the Ld. AO asked the assessee to produce the documentary evidence in respect of salary received during the year and also to furnish the details with respect to purchase of immovable property amounting

THE SOCIETY OF JESUS MARY JOSEPH SNEHALAYA,MANGALAGIRI vs. INCOME-TAX OFFICER,WARD-2(1), GUNTUR

In the result, appeal of the assessee is allowed for statistical purposes

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

144 of the Income Tax Act, 1961 (in short ‘Act’) dated 08.12.2023 for the A.Y. 2015-16. 2. Brief facts of the case are that, assessee is registered under Societies Registration Act, 1860 and also got registered under section 12A of IT Act, 1961 vide proceedings of CIT, Guntur No. 1/137/GNT/87-88 dated 28.12.1990. Specific information was flagged as per Risk

SIVA DURGA VARA PRASAD CHENNUPATI,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), VIJAYAWADA

In the result, the appeal by the assessee is allowed

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailita No.368/Viz/2025 (Assessment Year 2016-17) (Assessment Year 2016-17) Sivadurgavara Prasad Chennupati, H. No. 27-32-27, Raghu Paints, Mudda Subbaiah Street, Governorpet, Vijayawada ............... Appellant Pan: Aeepc5404L V/S Assistant Commissioner Of Income Tax, Circle – 2(1), ……………… Respondent C R Building, 1St Floor Annex, M.G. Road, Vijayawada Assessee By : Shri C.R. Hemanth Kumar, Ca Revenue By : Dr. Aparna Villuri, Sr. Ar

144 r.w.s 144B are bad in law.” 4. Since the issues raised by way of additional grounds are legal issues, which can be decided on the basis of material available on record, therefore, the same are admitted in view of the ratio laid down by the Hon’ble Supreme Court in NTPC vs CIT, reported