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

Section 14A, The Circular concludes that it is not necessary that exempt income should necessarily be included in a particular year's income for the disallowance to be triggered. 19

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:

19 (SC). It is contended that the AO disallowed the deduction under section 80P in the computation sheet without communicating

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 72AB of the Act. In the present case, the amalgamating company i.e. Bobbili Co-operative bank not filed return of income as required u/s 72AB of the Act. Therefore, the claim of the assessee cannot be allowed. We find that the Ld. CIT(A) has correctly decided the issue and disallowed the claim of the assessee.” 14. Insofar

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 72AB of the Act. In the present case, the amalgamating company i.e. Bobbili Co-operative bank not filed return of income as required u/s 72AB of the Act. Therefore, the claim of the assessee cannot be allowed. We find that the Ld. CIT(A) has correctly decided the issue and disallowed the claim of the assessee.” 14. Insofar

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 72AB of the Act. In the present case, the amalgamating company i.e. Bobbili Co-operative bank not filed return of income as required u/s 72AB of the Act. Therefore, the claim of the assessee cannot be allowed. We find that the Ld. CIT(A) has correctly decided the issue and disallowed the claim of the assessee.” 14. Insofar

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.

19. Apropos the disallowance made by the AO under Section 14A r.w Rule 8D of Rs. 15,42,448/- that

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.

19. Apropos the disallowance made by the AO under Section 14A r.w Rule 8D of Rs. 15,42,448/- that

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), GUNTUR vs. NSL TEXTILES LIMITED, HYDERABAD

In the result, appeal filed by the Revenue as well as cross objection filed by the assessee is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleacit, Circle-2(1), Vs. M/S. Nsl Textiles Ltd., Nsl Icon, 4Th Floor, D.No. Guntur. 8-2-684/2/A, Banjara Hills, Road No. 12, Hyderabad. Pan No. Aabcj 1299 A (Appellant) (Respondent)

Section 14A, The Circular concludes that it is not necessary that exempt income should necessarily be included in a particular year's income for the disallowance to be triggered. 19

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

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

19. The Hon’ble Madras High Court in the case of CIT v. S. Khader Khan Son (2008) 300 ITR 157 (Madras) has laid down the ratio that admissions made during statement recorded under section 133A of the Act would not automatically bound on the assessee. Further there is also merit in the argument of the Ld.AR that

SRI LUXMI TULASI AGRO PAPERS PVT LTD,RAJAHMUNDRY vs. ASSISTNT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJAHMUNDRY

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.195 & 196/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2010-11 & 2012-13)) Sri Luxmi Tulasi Agro Papers (P.) Ltd., V. Joint Commissioner Of Income Tax Rajahmundry Range D.No. 25-2-20, Jayakrishnapuram Aayakar Bhavan Annexe Rajamundry – 533105 Veerabhadrapuram Andhra Pradesh Kambala Cheruvu Rajamahendravaram [Pan: Aaecs2798A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowed the claim made by the assessee under section 80IA of the Act for an amount of Rs. 61,19

SRI LUXMI TULASI AGRO PAPERS PVT LTD,RAJAHMUNDRY vs. JOINT COMMISSIONER OF INCOME TAX, RAJAHMUNDRY RANGE, RAJAHMUNDRY

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.195 & 196/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2010-11 & 2012-13)) Sri Luxmi Tulasi Agro Papers (P.) Ltd., V. Joint Commissioner Of Income Tax Rajahmundry Range D.No. 25-2-20, Jayakrishnapuram Aayakar Bhavan Annexe Rajamundry – 533105 Veerabhadrapuram Andhra Pradesh Kambala Cheruvu Rajamahendravaram [Pan: Aaecs2798A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowed the claim made by the assessee under section 80IA of the Act for an amount of Rs. 61,19