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, 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, 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

MOHAMMED ALI SHAIK, ,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-2(4), , VIJAYAWADA

In the result, appeal filed by the Assessee stands partly allowed

Bench: Shri N.K. Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon'Ble

section 40A(3) were not applicable. However, the AO did not get impressed and made the disallowance of Rs. 1,35

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

sections 36 to 37 of the Act, hence, the same is disallowed and added back to the total income of the assessee. 35. On appeal, ld. CIT(A) by following the decision in assessee’s own case for the Assessment Year 2008-09 & 2009-10 and also CBDT Instruction No. 17/2008, dated 26/11/2008 directed the AO to examine whether these

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

sections 36 to 37 of the Act, hence, the same is disallowed and added back to the total income of the assessee. 35. On appeal, ld. CIT(A) by following the decision in assessee’s own case for the Assessment Year 2008-09 & 2009-10 and also CBDT Instruction No. 17/2008, dated 26/11/2008 directed the AO to examine whether these

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

sections 36 to 37 of the Act, hence, the same is disallowed and added back to the total income of the assessee. 35. On appeal, ld. CIT(A) by following the decision in assessee’s own case for the Assessment Year 2008-09 & 2009-10 and also CBDT Instruction No. 17/2008, dated 26/11/2008 directed the AO to examine whether these

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

In the result, the appeal filed by the assessee society is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.456/Viz/2025 (िनधा"रण वष"/Assessment Year:2019-20) No.368 Kolakaluru Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-1, Credit Society Limited, Tenali. Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: 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 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W Section 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated

disallowance of deduction claimed u/s 80P(2)(a)(i) of the Act. 4. Any other ground that may be urged at the time of appeal hearing." 2. Succinctly stated, the AO based on information disseminated in accordance with the Risk Management Strategy (RMS), which revealed that the assessee society had during the subject year made cash deposits/withdrawals aggregating

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:

35-39 of APB. Elaborating further on his contention, the Ld. AR submitted that now when the AO vide his order passed under section 143(3) r.w.s 143(3A & 143(3B) of the Act, dated 10/02/2021, had specifically observed that no addition was being made on the issue for which the case of the assessee society was selected for “limited

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. M/S. VISAKHAPATNAM PORT AUTHORITY, 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)

35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1,62,04,753 Gratuity Fund 7. Disallowance of amount paid

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)

35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1,62,04,753 Gratuity Fund 7. Disallowance of amount paid

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)

35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1,62,04,753 Gratuity Fund 7. Disallowance of amount paid

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, 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)

35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1,62,04,753 Gratuity Fund 7. Disallowance of amount paid

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)

35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1,62,04,753 Gratuity Fund 7. Disallowance of amount paid

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, 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)

35,64,651 3. Disallowance of prior period expenses 17,39,609 4. Disallowance of donation and contribution 84,97,821 5. Disallowance of excess claim on account of contribution to 139,66,89,155 36 pension fund 6. Disallowance of excess claim on account of contribution to 1,62,04,753 Gratuity Fund 7. Disallowance of amount paid