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-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

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

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

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 GUNDUGOLANU LARGE SIZE COOPERATIVE SOCIETY LIMITED ,GUNDUGOLANU vs. NFAC, DELHI

disallowed a deduction of Rs. 68,25,879/- under section 80P(2)(a)(i) and also disallowed a deduction of Rs. 65,462/- under

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

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

disallowance of deduction u/s 80P(2)(a)(i) of Rs. 5,25,763/- is\nerroneous andunjustified. The Appellant's core activity is providing\nagricultural credit to itsmembers in accordance with its by-laws, and all\nsuch transactions are dulyrecorded in the audited books of accounts.\n3. In the case of present appellant, AY 2018-19, a larger cash deposit

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

disallowed in the computation of income.\nHowever, Rs 20 lacs was erroneously reported in Form 3CD and hence\ndisallowed during processing of ITR u/s 143(1). Similarly form 3CD has\n22\nITA No.314 & 206/Viz/2025\nITA No. 205/Viz/2024\nNord Anglia Education Infrastructure\nPrivate Limited vs. DCITT\nreported wrong figure of Rs 6.77 lacs as non compliance with chapter\nXVII

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

disallowance of deduction u/s 80P(2)(a)(i) of Rs. 5,25,763/- is\nerroneous andunjustified. The Appellant's core activity is providing\nagricultural credit to itsmembers in accordance with its by-laws, and all\nsuch transactions are dulyrecorded in the audited books of accounts.\n3. In the case of present appellant, AY 2018-19, a larger cash deposit

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

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

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

disallowance of deduction u/s 80P(2)(a)(i) of Rs. 5,25,763/- is\nerroneous andunjustified. The Appellant's core activity is providing\nagricultural credit to itsmembers in accordance with its by-laws, and all\nsuch transactions are dulyrecorded in the audited books of accounts.\n3.\nIn the case of present appellant, AY 2018-19, a larger cash deposit

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), , VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED,, VISAKHAPATNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowances of Rs. 91,79,472/- being the payment to bogus nature of sub-contract works. This ground is similar to ground Nos. 2 & 3 raised by the revenue in ITA No. 50/Viz/2021 for the A.Y.2013-14 and the decision rendered therein shall apply mutatis-mutandis for Page No. 12 I.T.A.Nos.50, 51 & 53/VIZ/2021 M/s. Alfa Electronic Services (India) Private Limited

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED, VISAKHAPTNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowances of Rs. 91,79,472/- being the payment to bogus nature of sub-contract works. This ground is similar to ground Nos. 2 & 3 raised by the revenue in ITA No. 50/Viz/2021 for the A.Y.2013-14 and the decision rendered therein shall apply mutatis-mutandis for Page No. 12 I.T.A.Nos.50, 51 & 53/VIZ/2021 M/s. Alfa Electronic Services (India) Private Limited