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

25,468/- (Under section 37(1) of the Act Rs.14,92,734/- and under section 40A(3) of the Act Rs.9,32,734/- iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also 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

25,468/- (Under section 37(1) of the Act Rs.14,92,734/- and under section 40A(3) of the Act Rs.9,32,734/- iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also 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

25,468/- (Under section 37(1) of the Act Rs.14,92,734/- and under section 40A(3) of the Act Rs.9,32,734/- iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also 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

25,468/- (Under section 37(1) of the Act Rs.14,92,734/- and under section 40A(3) of the Act Rs.9,32,734/- iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also 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

25,468/- (Under section 37(1) of the Act Rs.14,92,734/- and under section 40A(3) of the Act Rs.9,32,734/- iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also 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

25,468/- (Under section 37(1) of the Act Rs.14,92,734/- and under section 40A(3) of the Act Rs.9,32,734/- iii. Patient refund account : Rs.5,04,366/- (Under section 37 of the Act) iv. Other expenditure : Rs.9,92,990/- (Under section 40A(3) of the Act) 5. Further Ld. AO also disallowed

DY CIT, VISAKHAPATNAM vs. KOTU SARATH KUMAR`, 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

disallowance is called for u/s 14A of the Act in the absence of exempt income. Accordingly, the order of the Ld. CIT(A) on this issue is set aside and this ground of appeal of the assessee is allowed.‖ 5. Since the facts of the case are identical, respectfully following the view taken by the Hon’ble High Court

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

disallowance is called for u/s 14A of the Act in the absence of exempt income. Accordingly, the order of the Ld. CIT(A) on this issue is set aside and this ground of appeal of the assessee is allowed.‖ 5. Since the facts of the case are identical, respectfully following the view taken by the Hon’ble High Court

KOTU ANASUYA (LATE),VISAKHAPATNAM vs. DCIT, 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

disallowance is called for u/s 14A of the Act in the absence of exempt income. Accordingly, the order of the Ld. CIT(A) on this issue is set aside and this ground of appeal of the assessee is allowed.‖ 5. Since the facts of the case are identical, respectfully following the view taken by the Hon’ble High Court

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:

disallowance of the assessee’s claim for deduction under section 80P of the Act of Rs. 84,01,387/-, i.e., the solitary deduction that was claimed by the assessee society in its return of income under Chapter VI-A. On the contrary, we find that the AO, while framing the assessment, had specifically observed that in view of the material

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.

disallowance under Section 14A of the Act was liable to be restricted to the extent of the exempt income received by the assessee company during the subject year; and (iii). sustainability of the CIT(A) order, in the backdrop of the fact that he had, in the course of hearing of the appeal, admitted certain “additional evidence”, viz. (a). copy

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.

disallowance under Section 14A of the Act was liable to be restricted to the extent of the exempt income received by the assessee company during the subject year; and (iii). sustainability of the CIT(A) order, in the backdrop of the fact that he had, in the course of hearing of the appeal, admitted certain “additional evidence”, viz. (a). copy

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , KAKINADA vs. CRESCO TECHNOLOGY PRIVATE LIMITED, BALABADRAPURAM

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleacit, Circle-1, Vs. M/S. Cresco Technology Pvt. Kakinada. Ltd., D.No. 8-256, Tata Nagar, Balabadrapuram, East Godavari District. Pan No. Aaacc 9848 F (Appellant) (Respondent)

section 14A read with rule 8D of I.T. Rules, 1962. 3. In the assessment order, the Assessing Officer has noted as under:- (M/s. Cresco Technology Pvt. Ltd.) 2. During the course of assessment proceedings, it was observed that the assessee company has made investment amounting to Rs.27,25,28,651/- in Equity Shares during the year and earned Exempt-income

INCOMETAX OFFICER , BHIMAVARAM vs. PRASAD RAJU PENMATSA, BHIMAVARAM

In the result, appeal of the revenue is allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.517/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Income Tax Officer-Ward – 1 Penmatsa Prasad Raju D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Jp Road, Sivaraopet Andhra Pradesh Bhimavaram – 534201 Andhra Pradesh [Pan:Aqcpp6707B] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.33/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Penmatsa Prasad Raju Income Tax Officer D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Opp. Ganesh Canteen Andhra Pradesh Jp Road, Sivaraopet Bhimavaram – 534202 [Pan:Aqcpp6707B] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Gvn Hari, Advocate करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

disallowed 25% of the purchases based on non-submission of purchase bills for verification of the genuineness of the purchases. However, the Ld. CIT(A) took an alternative view by estimating the profit @2% on the turnover. It is observed that neither Page. No 5 I.T.A.No.517/VIZ/2024 I.T.A.No.33/VIZ/2025 Penmatsa Prasad Raju of the Revenue Authorities has invoked provision

PENMATSA PRASAD RAJU,BHIMAVARAM vs. INCOME TAX OFFICER, WARD-1, BHIMAVARAM

In the result, appeal of the revenue is allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.517/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Income Tax Officer-Ward – 1 Penmatsa Prasad Raju D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Jp Road, Sivaraopet Andhra Pradesh Bhimavaram – 534201 Andhra Pradesh [Pan:Aqcpp6707B] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.33/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Penmatsa Prasad Raju Income Tax Officer D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Opp. Ganesh Canteen Andhra Pradesh Jp Road, Sivaraopet Bhimavaram – 534202 [Pan:Aqcpp6707B] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Gvn Hari, Advocate करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

disallowed 25% of the purchases based on non-submission of purchase bills for verification of the genuineness of the purchases. However, the Ld. CIT(A) took an alternative view by estimating the profit @2% on the turnover. It is observed that neither Page. No 5 I.T.A.No.517/VIZ/2024 I.T.A.No.33/VIZ/2025 Penmatsa Prasad Raju of the Revenue Authorities has invoked provision