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 40A(3) of the Act out of the expenditure incurred under patient refund account without bringing any corroborative evidences of such nature of payment. 4. The Learned CIT (Appeals) is not justified in directing the AO to estimate disallowance @ 25% out of the expenditure claimed under referral payments of Rs.34,84,567/- without any basis and any justifiable evidence

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 40A(3) of the Act out of the expenditure incurred under patient refund account without bringing any corroborative evidences of such nature of payment. 4. The Learned CIT (Appeals) is not justified in directing the AO to estimate disallowance @ 25% out of the expenditure claimed under referral payments of Rs.34,84,567/- without any basis and any justifiable evidence

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 40A(3) of the Act out of the expenditure incurred under patient refund account without bringing any corroborative evidences of such nature of payment. 4. The Learned CIT (Appeals) is not justified in directing the AO to estimate disallowance @ 25% out of the expenditure claimed under referral payments of Rs.34,84,567/- without any basis and any justifiable evidence

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 40A(3) of the Act out of the expenditure incurred under patient refund account without bringing any corroborative evidences of such nature of payment. 4. The Learned CIT (Appeals) is not justified in directing the AO to estimate disallowance @ 25% out of the expenditure claimed under referral payments of Rs.34,84,567/- without any basis and any justifiable evidence

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 40A(3) of the Act out of the expenditure incurred under patient refund account without bringing any corroborative evidences of such nature of payment. 4. The Learned CIT (Appeals) is not justified in directing the AO to estimate disallowance @ 25% out of the expenditure claimed under referral payments of Rs.34,84,567/- without any basis and any justifiable evidence

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 40A(3) of the Act out of the expenditure incurred under patient refund account without bringing any corroborative evidences of such nature of payment. 4. The Learned CIT (Appeals) is not justified in directing the AO to estimate disallowance @ 25% out of the expenditure claimed under referral payments of Rs.34,84,567/- without any basis and any justifiable evidence

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 was called for in its case under Section 14A of the Act. 30. We have thoughtfully considered the contentions advanced by the Ld. Authorised Representatives of both parties in the backdrop of the orders of the authorities below. 31. At the threshold, we may herein observe that there is no substance in the claim of the revenue that

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 was called for in its case under Section 14A of the Act. 30. We have thoughtfully considered the contentions advanced by the Ld. Authorised Representatives of both parties in the backdrop of the orders of the authorities below. 31. At the threshold, we may herein observe that there is no substance in the claim of the revenue that

SRI LUXMI TULASI AGRO PAPERS PVT LTD,RAJAHMUNDRY vs. ASSISTNT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJAHMUNDRY

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.195 & 196/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2010-11 & 2012-13)) Sri Luxmi Tulasi Agro Papers (P.) Ltd., V. Joint Commissioner Of Income Tax Rajahmundry Range D.No. 25-2-20, Jayakrishnapuram Aayakar Bhavan Annexe Rajamundry – 533105 Veerabhadrapuram Andhra Pradesh Kambala Cheruvu Rajamahendravaram [Pan: Aaecs2798A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 80IA of the Act for an amount of Rs. 61,19,772/-. Further Assessing Officer also disallowed the remuneration debited to Profit & Loss Account for an amount of Rs. 22,00,000/- and Rs. 3,34

SRI LUXMI TULASI AGRO PAPERS PVT LTD,RAJAHMUNDRY vs. JOINT COMMISSIONER OF INCOME TAX, RAJAHMUNDRY RANGE, RAJAHMUNDRY

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.195 & 196/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2010-11 & 2012-13)) Sri Luxmi Tulasi Agro Papers (P.) Ltd., V. Joint Commissioner Of Income Tax Rajahmundry Range D.No. 25-2-20, Jayakrishnapuram Aayakar Bhavan Annexe Rajamundry – 533105 Veerabhadrapuram Andhra Pradesh Kambala Cheruvu Rajamahendravaram [Pan: Aaecs2798A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 80IA of the Act for an amount of Rs. 61,19,772/-. Further Assessing Officer also disallowed the remuneration debited to Profit & Loss Account for an amount of Rs. 22,00,000/- and Rs. 3,34

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)

34. Brief facts of the case are that, the Assessee is engaged in the activity of Design and Development of various Electronic Systems belonging to Missiles, War Ships and War Air crafts etc., of Ministry of Defence. Survey under section 133A of the Actwas carried out at the business premises of the assessee on 15.12.2015. During the course of Survey

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)

34. Brief facts of the case are that, the Assessee is engaged in the activity of Design and Development of various Electronic Systems belonging to Missiles, War Ships and War Air crafts etc., of Ministry of Defence. Survey under section 133A of the Actwas carried out at the business premises of the assessee on 15.12.2015. During the course of Survey

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)

34. Brief facts of the case are that, the Assessee is engaged in the activity of Design and Development of various Electronic Systems belonging to Missiles, War Ships and War Air crafts etc., of Ministry of Defence. Survey under section 133A of the Actwas carried out at the business premises of the assessee on 15.12.2015. During the course of Survey

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.

disallowance can be made under section 43B of the Act. 4. In the light of the Supreme Court's decision in the matter, the issue is well settled. Accordingly. the Board has decided that no appeals may henceforth be filed on this ground by the officers of the Department and appeals already filed, if any, on this ground before Courts/Tribunals

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)

section 40(a)(iib) of the Act on the following issue: Amount paid of Rs. 20,61,81,938/- as per GOMs No. 39, dated 02/04/2002 for water supplied by AP irrigation & CAD (PW: QC&IWS/COD) Department (Now Water Resource Department of Andhra Pradesh State Government. He ought to have considered the fact that, the issues considered for disallowance

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)

section 40(a)(iib) of the Act on the following issue: Amount paid of Rs. 20,61,81,938/- as per GOMs No. 39, dated 02/04/2002 for water supplied by AP irrigation & CAD (PW: QC&IWS/COD) Department (Now Water Resource Department of Andhra Pradesh State Government. He ought to have considered the fact that, the issues considered for disallowance

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)

section 40(a)(iib) of the Act on the following issue: Amount paid of Rs. 20,61,81,938/- as per GOMs No. 39, dated 02/04/2002 for water supplied by AP irrigation & CAD (PW: QC&IWS/COD) Department (Now Water Resource Department of Andhra Pradesh State Government. He ought to have considered the fact that, the issues considered for disallowance

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)

section 40(a)(iib) of the Act on the following issue: Amount paid of Rs. 20,61,81,938/- as per GOMs No. 39, dated 02/04/2002 for water supplied by AP irrigation & CAD (PW: QC&IWS/COD) Department (Now Water Resource Department of Andhra Pradesh State Government. He ought to have considered the fact that, the issues considered for disallowance