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.

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

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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. The Ld. CIT(A) has examined the submissions made by the Ld.AR and has held in para no 6.5.1 as follows: “6.5.1 Consultation Fees paid (Rs.84,01,360/-) :- Out of the total consultancy charges paid of Rs.91,24,989/-, the Assessing Officer had disallowed

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

section 14A of the Act\nprovides for disallowance of the expenditure even where taxpayer in a\nparticular year has not earned any exempt income.\nGround 5. The appellant craves leave to add or delete or amend or\nsubstitute any ground of appeal before and/or at the time of hearing of\nappeal For these and other grounds that may be urged

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

24,110/- after making adjustment to the returned income.\nThereafter the case was selected for limited scrutiny for verification of\ndeduction claimed under section 80P of the Act. Accordingly, statutory notices\nunder section 143(2) and 142(1) of the Act were issued and served on the\nassessee, calling for information. In response filed its submissions. On perusal

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

section 36(1)(va) r.w.s. 2(24)(x) of the Act, leading to disallowance of this sum to the extent

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

section 36(1)(va) r.w.s. 2(24)(x) of the Act, leading to disallowance of this sum to the extent

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

section 36(1)(va) r.w.s. 2(24)(x) of the Act, leading to disallowance of this sum to the extent

DASARI BUJJI,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1(1), VISAKHAPATNAM

In the result, appeal of the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.20/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) Dasari Bujji Vs. Income Tax Officer D.No.40-54-5/31 Ward-1(1) Sanjeevayya Colony, Visakhapatnam Near Bethadha Church, Tatichetlapalem, Visakhapatnam [Pan : Bklpd8566J]

section 36(1)(va) r.w.s. 2(24)(x) of the Act, leading to disallowance of this sum to the extent

SRI RANGA MOTORS,VIZIANAGARAM vs. INCOME TAX OFFICE, WARD-1, VIZIANAGARAM

In the result, appeals of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.175/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Eastern Warehouse Corporation Vs. Income Tax Officer Visakhapatnam Ward-1(1) [Pan : Aaafe3741J] Visakhapatnam आयकर अपील सं./I.T.A.No.179/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Sri Ranga Motors Vs Income Tax Officer Vizianagaram Ward-1 [Pan : Aabbfs8249P] Vizianagaram आयकर अपील सं./I.T.A.No.174/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) Tetali Anil Kumar Vs. Income Tax Officer Visakhapatnam Ward-3(3) [Pan : Aaqpt9453L] Visakhapatnam आयकर अपील सं./I.T.A.No.184/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) T.Srinivasa Rao & Co. Vs. Income Tax Officer Visakhapatnam Ward-1(1) [Pan : Aamft1310Q] Visakhapatnam

section 36(1)(va) r.w.s. 2(24)(x) of the Act, leading to disallowance of this sum to the extent

T SRINIVASA RAO&CO,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1(1), VISAKHAPATNAM

In the result, appeals of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.175/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Eastern Warehouse Corporation Vs. Income Tax Officer Visakhapatnam Ward-1(1) [Pan : Aaafe3741J] Visakhapatnam आयकर अपील सं./I.T.A.No.179/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Sri Ranga Motors Vs Income Tax Officer Vizianagaram Ward-1 [Pan : Aabbfs8249P] Vizianagaram आयकर अपील सं./I.T.A.No.174/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) Tetali Anil Kumar Vs. Income Tax Officer Visakhapatnam Ward-3(3) [Pan : Aaqpt9453L] Visakhapatnam आयकर अपील सं./I.T.A.No.184/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) T.Srinivasa Rao & Co. Vs. Income Tax Officer Visakhapatnam Ward-1(1) [Pan : Aamft1310Q] Visakhapatnam

section 36(1)(va) r.w.s. 2(24)(x) of the Act, leading to disallowance of this sum to the extent

EASTERN WAREHOUSE CORPORATION,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1(1), VISAKHAPATNAM

In the result, appeals of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.175/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Eastern Warehouse Corporation Vs. Income Tax Officer Visakhapatnam Ward-1(1) [Pan : Aaafe3741J] Visakhapatnam आयकर अपील सं./I.T.A.No.179/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Sri Ranga Motors Vs Income Tax Officer Vizianagaram Ward-1 [Pan : Aabbfs8249P] Vizianagaram आयकर अपील सं./I.T.A.No.174/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) Tetali Anil Kumar Vs. Income Tax Officer Visakhapatnam Ward-3(3) [Pan : Aaqpt9453L] Visakhapatnam आयकर अपील सं./I.T.A.No.184/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) T.Srinivasa Rao & Co. Vs. Income Tax Officer Visakhapatnam Ward-1(1) [Pan : Aamft1310Q] Visakhapatnam

section 36(1)(va) r.w.s. 2(24)(x) of the Act, leading to disallowance of this sum to the extent