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

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:

disallowed the assessee’s claim for deduction under section 80P of the Act of Rs.84,01,387/- and computed the consequential tax liability in its hands. 15

DCIT, CIRCLE - 3(1), , VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

disallowance\nmade u/s.14A of Rs. 15,42,448/- to Rs. 20,585/- merely by relying on\nthe judicial pronouncements of various courts relied by the assessee.\nThis decision of Ld.CIT(A) is not in accordance with 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

section 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

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 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

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 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

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 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

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 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

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 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

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 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

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 37(1) of the Act. Ld. DR also relied on the decision of jurisdictional coordinate bench of the Tribunal in the case of Chalasani Hospitals (P.) Ltd., v. ACIT [2024] 165 taxmann.com 753 (Visakhapatnam – Trib.). He therefore pleaded that the Ld.CIT(A) has erred in estimating the disallowance made which is bad in law. He therefore prayed for restoring

THE VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASST. CIT,, 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)

section 14A are not applicable. 4. (a) The Ld. CIT(A) is not justi8fied in confirming the disallowance of alleged excess depreciation of Rs. 5,20,74,400/- claimed in respect of capital dredging. (b) The Ld. CIT(A) ought to have appreciated that capital dredging is a plant and machinery and hence the appellant is entitled for depreciation @ 15

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)

section 14A are not applicable. 4. (a) The Ld. CIT(A) is not justi8fied in confirming the disallowance of alleged excess depreciation of Rs. 5,20,74,400/- claimed in respect of capital dredging. (b) The Ld. CIT(A) ought to have appreciated that capital dredging is a plant and machinery and hence the appellant is entitled for depreciation @ 15

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)

section 14A are not applicable. 4. (a) The Ld. CIT(A) is not justi8fied in confirming the disallowance of alleged excess depreciation of Rs. 5,20,74,400/- claimed in respect of capital dredging. (b) The Ld. CIT(A) ought to have appreciated that capital dredging is a plant and machinery and hence the appellant is entitled for depreciation @ 15

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)

section 14A are not applicable. 4. (a) The Ld. CIT(A) is not justi8fied in confirming the disallowance of alleged excess depreciation of Rs. 5,20,74,400/- claimed in respect of capital dredging. (b) The Ld. CIT(A) ought to have appreciated that capital dredging is a plant and machinery and hence the appellant is entitled for depreciation @ 15

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)

section 14A are not applicable. 4. (a) The Ld. CIT(A) is not justi8fied in confirming the disallowance of alleged excess depreciation of Rs. 5,20,74,400/- claimed in respect of capital dredging. (b) The Ld. CIT(A) ought to have appreciated that capital dredging is a plant and machinery and hence the appellant is entitled for depreciation @ 15

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)

section 14A are not applicable. 4. (a) The Ld. CIT(A) is not justi8fied in confirming the disallowance of alleged excess depreciation of Rs. 5,20,74,400/- claimed in respect of capital dredging. (b) The Ld. CIT(A) ought to have appreciated that capital dredging is a plant and machinery and hence the appellant is entitled for depreciation @ 15

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, , VISAKHAPTNAM

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)

section 14A are not applicable. 4. (a) The Ld. CIT(A) is not justi8fied in confirming the disallowance of alleged excess depreciation of Rs. 5,20,74,400/- claimed in respect of capital dredging. (b) The Ld. CIT(A) ought to have appreciated that capital dredging is a plant and machinery and hence the appellant is entitled for depreciation @ 15