RANAR AGROCHEM LIMITED,PARAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

iv) by applying provisions of Section 36(1)(va) read with Section 2(24)(x) is found to be valid and proper in fact and law. Considering the totality of the facts and circumstances of the case, the disallowance

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, 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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. 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)

iv) CIT vs. Small Industries Development Bank of India [2012] 211 Taxman 341 9. The Ld. AR therefore pleaded that the order of the Ld. CIT-1, Visakhapatnam may be quashed. 15 Per contra, the Ld. Departmental Representative (Ld DR) relied on the orders of the Ld. PCIT and argued in support of the same. 10. We have heard both

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM vs. GUNTUBOLU UMA SAI PRASAD, VISAKHAPATNAM

In the result, appeal of the assessee is dismissed

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

24)(x) of the Act, leading to disallowance of this sum to the extent not paid on or before the due date stipulated in the respective PF and ESI Act.” Further, this Bench of the ITAT, Visakhapatnam (Single Member Bench) on identical circumstances discussed the issue ie., whether the CPC can make adjustments based on the information available before them

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM vs. GUNTUBOLU UMA SAI PRASAD, VISAKHAPATNAM

In the result, appeal of the assessee is dismissed

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

24)(x) of the Act, leading to disallowance of this sum to the extent not paid on or before the due date stipulated in the respective PF and ESI Act.” Further, this Bench of the ITAT, Visakhapatnam (Single Member Bench) on identical circumstances discussed the issue ie., whether the CPC can make adjustments based on the information available before them

GUNTUBOLU UMA SAI PRASAD,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

In the result, appeal of the assessee is dismissed

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

24)(x) of the Act, leading to disallowance of this sum to the extent not paid on or before the due date stipulated in the respective PF and ESI Act.” Further, this Bench of the ITAT, Visakhapatnam (Single Member Bench) on identical circumstances discussed the issue ie., whether the CPC can make adjustments based on the information available before them

ARRDY ENGINNERING INNOVATIONS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

disallowance has resulted in additional tax liability and interest thereon. 2. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field trials incurred at Rourkela (on the ground that the same was not covered under the definition of approved in-house R & D house and this

ARRDY ENGINEERING INNOVATINS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

disallowance has resulted in additional tax liability and interest thereon. 2. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field trials incurred at Rourkela (on the ground that the same was not covered under the definition of approved in-house R & D house and this

INCOMETAX OFFICER, WARD-3(1), VISAKHAPATNAM vs. SURENDRA NATH GUBBALA, VISAKHAPATNAM

Bench: Us:

disallowance made by the AO. The Ld. AR to fortify his contention that the assessee’s claim for deduction of the amount of Rs. 9 crores (supra) had rightly been allowed by the CIT(A), relied on a host of judicial pronouncements. 16 ITA No.482/Viz/2024 & CO No.03/Viz/2025 Surendra Nath Gubbala 12. We have heard the Ld. Authorised Representatives of both

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

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Disallowance of excess claim on account of contribution to 2,49,03,33,905 pension fund Accordingly, the Ld. AO determined the total income of the assessee at Rs. 3,02,98,39,640/- and passed the assessment order U/s. 143(3) of the Act on 31/3/2016. Aggrieved by the order of the Ld.AO, the assessee preferred an appeal before