VENKATA PRASAD PULIPATI,AMARAVATHI vs. INCOME-TAX OFFICER, WARD-2(1), GUNTUR

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.612/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Venkata Prasad Pulipati, Vs. Income Tax Officer, Amaravathi. Ward-2(1), Pan: Asapp8796L Guntur. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri I. Kama Sastry, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order

1), Guntur, instead of the National Faceless Assessment Centre. 5. The Notice issued under section 148 dated 27.07.2022 is invalid as the same is issued without DIN and the reasons for not being able to generate DIN are not mentioned in the body of the notice. 6. The Notice issued under section 148 dated 27.07.2022 is invalid as the copy

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

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

disallowed because the return was filed under Section 139(4) and not within the due date under Section 139(1), as per Section 80AC.", "result": "Allowed/Dismissed/Partly Allowed/Remanded", "sections": [ "147", "144", "139(1)", "148

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

disallowance of deduction of\nRs.2,40,747/- under Section 80P(2)(a)(i) of the Income Tax Act, 1961\nsolely on the ground that the return was filed beyond the due date\nspecified under Section 139(1), without appreciating that the Appellant\nhad filed a valid return in compliance with the notice u/s 148

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

disallowance of deduction of\nRs.2,40,747/- under Section 80P(2)(a)(i) of the Income Tax Act, 1961\nsolely on the ground that the return was filed beyond the due date\nspecified under Section 139(1), without appreciating that the Appellant\nhad filed a valid return in compliance with the notice u/s 148

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)

1. The learned Commissioner of Income-Tax (Appeals) is justified in quashing the notice issued u/s 148 by the jurisdictional Assessing officer contrary to the provisions of 'E-Assessment of Income Escaping Assessment Scheme' which stipulates that a notice u/s 148 can be issued after 29.03.2022 only by the Faceless Assessing officer. 2. The learned Commissioner of Income-Tax (Appeals

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

Section 151A of the Act. 3. Without prejudice to the above, the Ld. CIT(A) is not justified in sustaining the addition of Rs. 14,81,568/- made by the Assessing Officer towards 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

OMMI SANDEEP,VIZIANAGARAM vs. INCOME TAX OFFICER, WARD-1, VIZIANAGARAM

1)\nand section 148, the returns were nonest and could not have been acted\nupon by the Assessing Officer even though they were filed before the\ncompletion of the assessment. (AY.2009-10, 2010-11)\n2.\nDecision of Hon'ble ITAT, Visakhapatnam in the case of Maruthi\nPrimary Agricultural Cooperative Credit Society Ltd. Vs Income Tax\nOfficer, Ward-3(5), Vijayawada, Vide

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

148 of the Act on\n09.04.2022. Section 80A sub-section 5 of the Act is reproduced below for\nreference: -\n\n\"80A\n(5)\nWhere the assessee fails to make a claim in his return of income\nfor any deduction under section 10A or section 10AA or section 10B or\nsection 10BA or under any provision of this Chapter under

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. VENKATRAMA POULTRIES PVT. LTD, GUNTUR

disallowed bogus purchases at 10%.", "result": "Dismissed", "sections": [ "Section 132", "Section 133A", "Section 147", "Section 148", "Section 142(1)", "Section

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. VENKATA SITA RAMACHANDRA RAO KANCHUMARTHY, RAJAHMUNDRY

In the result, appeal of the revenue is dismissed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.352/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2016-17) Vs. Dy. Commissioner Of Income Tax Venkata Sita Ramachandra Rao Kanchumarty International Taxation, Circle H.No. 26-22-16 Ground Floor, Infinity Tower Near Chinna Anjaneya Swamy Temple Sankarmattam Road Danavaipeta, Rajahmundry Visakhapatnam – 530016 East Godavari District – 533103 Andhra Pradesh Andhra Pradesh [Pan:Edzpk3519Q]

148 of the Act on 31.03.2018 admitting a total income of Rs.2,92,55,358/-. In response to notices under section 143(2) and 142(1) of the Act assessee’s representatives filed requisite information called for. Ld.Assessing Officer [hereinafter in short “Ld. AO"] during the course of scrutiny proceedings recomputed the Long-Term Capital Gains at Rs.9

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)

1, 2 & 3 are dismissed. 15. On merits, Ld.AR argued that with respect to Ground No. 4 by stating that the assessee has filed return of income in response to notice under section 148 of the Act belatedly and therefore entitled for deduction under section 80P of the Act. Ld.AR therefore pleaded to delete the disallowances

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

disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses

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

disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses

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

disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses

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

disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses

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

disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses

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

disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses

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

disallowed under section 37(1) under section 148(A) of the Act an amount of Rs.71,14,092/- considering the expenses