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

Section 194-I of the Act, yet the income so received\nwas assessable in the hands of the assessee firm as its \"Income from\nbusiness" and not as “Income from house property". Also, a similar view\nhad been taken by a coordinate bench of ITAT, Kolkata in the case of\nDCIT Vs Tewari Warehousing Co. (2018) 92 taxmann.com

ACIT, CIRCLE-2(1), VISAKHAPATNAM vs. VIZAG SEAPORT PVT. LTD., VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon‟Ble & Shri S Balakrishnan, Hon‟Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No. 383/Viz/2017 (धनधाारणिर्ा/ Assessment Year : 2012-13) The Assistant Commissioner Of Vs. M/S. Vizag Seaport Pvt Ltd., Income Tax, Administrative Block, Circle-5(1), S4 Gallery, Port Area, Visakhapatnam. Visakhapatnam – 530035. (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent) [Pan :Aabcv2484K] अपीलाथी की ओर से/ Assessee By : Sri Fenil A Bhatt, Ar प्रत्याथी की ओर से/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुनिाई की तारीख/ Date Of Hearing : 15/02/2024 घोर्णा की तारीख/Date Of : /04/2024 Pronouncement O R D E R Pers. Balakrishnan:

disallowance under section 40a(ia) of the Act cannot be made and the correct course of action would have been to invoke Section 201 of the Act. On similar facts, the Calcutta High Court in CIT v. S.K. Tekriwal [2014] 46 taxmann.com 444/361 ITR 432/[2013] 260 CTR 73/2012 SCC Online CAL 12147 dismissed the Revenue's appeal. The relevant

ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE1(1), VIJAYAWADA

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

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd assessee and cannot be considered as revenue income in the hands of the assessee for the impugned assessment year. Thus, the Ground No.2 raised by the assessee is allowed. 11. Ground No.3 is with respect to invoking of the provisions of section 14A of the Act by disallowing

ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), VIJAYAWADA

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

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd assessee and cannot be considered as revenue income in the hands of the assessee for the impugned assessment year. Thus, the Ground No.2 raised by the assessee is allowed. 11. Ground No.3 is with respect to invoking of the provisions of section 14A of the Act by disallowing

ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE 1(1), VIJAYAWADA

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

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd assessee and cannot be considered as revenue income in the hands of the assessee for the impugned assessment year. Thus, the Ground No.2 raised by the assessee is allowed. 11. Ground No.3 is with respect to invoking of the provisions of section 14A of the Act by disallowing

ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA

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

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd assessee and cannot be considered as revenue income in the hands of the assessee for the impugned assessment year. Thus, the Ground No.2 raised by the assessee is allowed. 11. Ground No.3 is with respect to invoking of the provisions of section 14A of the Act by disallowing

ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA

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

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd assessee and cannot be considered as revenue income in the hands of the assessee for the impugned assessment year. Thus, the Ground No.2 raised by the assessee is allowed. 11. Ground No.3 is with respect to invoking of the provisions of section 14A of the Act by disallowing

ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA

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

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd assessee and cannot be considered as revenue income in the hands of the assessee for the impugned assessment year. Thus, the Ground No.2 raised by the assessee is allowed. 11. Ground No.3 is with respect to invoking of the provisions of section 14A of the Act by disallowing

SRI SEETARAMANJANEYA SORTEX ,KAKINADA vs. PRINCIPALMCOMMISSIONER OF INCOME TAX , VISAKHAPATNAM

In the result, appeal of the assessee is dismissed

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.234/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19) Sri Seetaramanjaneya Sortex V. Pr.Cit Aayakar Bhavan 1-2015/A, Uppalanka Dabagardens – 530020 Kakinada – 533016, Andhra Pradesh Visakhapatnam, Andhra Pradesh [Pan: Abdfs4641P]

194 of the Act deduction of tax is not applicable on the interest payment to the banks. Further, he also reiterated on the non-applicability of the tax deduction at source for an amount of Rs.21,70,096/- stating that these are within the threshold limits for exemption for deduction of Page No. 3 I.T.A.No.234/VIZ/2024 Sri Seetaramanjaneya Sortex