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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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. He further submitted that the assessee has also not deducted tax at source on these payments. He therefore pleaded that order of the Ld. AO be upheld. 48. Per contra, Ld.AR submitted that these amounts paid to various visiting doctors specialised in various treatments. He further argued that these payments were not doubted

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.

Section 194-I of the Act, yet the income so received was assessable in the hands of the assessee firm as its “Income from business” and not as “Income from house property”. Also, a similar view had been taken by a coordinate bench of ITAT, Kolkata in the case of DCIT Vs Tewari Warehousing Co. (2018) 92 taxmann.com 168 Private

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.

Section 194-I of the Act, yet the income so received was assessable in the hands of the assessee firm as its “Income from business” and not as “Income from house property”. Also, a similar view had been taken by a coordinate bench of ITAT, Kolkata in the case of DCIT Vs Tewari Warehousing Co. (2018) 92 taxmann.com 168 Private

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)

48,72,600/- 4. Based on the statements recorded from the Managing Director during the survey operations, Assessing Officer made a disallowance amounting to Rs.1,55,42,604/- considering it as payment to bogus sub-contractors. Further, Assessing Officer also disallowed sum of Rs. 68,10,031/- in respect of VAT Payable under section

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)

48,72,600/- 4. Based on the statements recorded from the Managing Director during the survey operations, Assessing Officer made a disallowance amounting to Rs.1,55,42,604/- considering it as payment to bogus sub-contractors. Further, Assessing Officer also disallowed sum of Rs. 68,10,031/- in respect of VAT Payable under section

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)

48,72,600/- 4. Based on the statements recorded from the Managing Director during the survey operations, Assessing Officer made a disallowance amounting to Rs.1,55,42,604/- considering it as payment to bogus sub-contractors. Further, Assessing Officer also disallowed sum of Rs. 68,10,031/- in respect of VAT Payable under section

ACIT, CIRCLE-2(1), VISAKHAPATNAM vs. VIZAG SEAPORT PVT. LTD., VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon‟Ble & Shri S Balakrishnan, Hon‟Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No. 383/Viz/2017 (धनधाारणिर्ा/ Assessment Year : 2012-13) The Assistant Commissioner Of Vs. M/S. Vizag Seaport Pvt Ltd., Income Tax, Administrative Block, Circle-5(1), S4 Gallery, Port Area, Visakhapatnam. Visakhapatnam – 530035. (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent) [Pan :Aabcv2484K] अपीलाथी की ओर से/ Assessee By : Sri Fenil A Bhatt, Ar प्रत्याथी की ओर से/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुनिाई की तारीख/ Date Of Hearing : 15/02/2024 घोर्णा की तारीख/Date Of : /04/2024 Pronouncement O R D E R Pers. Balakrishnan:

48,088 + Rs. 1,53,838) Aggrieved by the above additions, the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A) while considering the submissions made by the assessee‟s Representative relied on the decision of his predecessor for the assessee‟s own case for the earlier assessment years and thereby partly allowed the appeal

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 made by the AO. 15. We shall now deal with the Ld. AR’s contention that the authorities below had erred in making/sustaining the addition of Rs. 3,47,97,000/- under section 68 of the Act. On a perusal of the record, we find that the assessee company had during the subject year received unsecured loans aggregating

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)

disallow payments made for supply of water and for payment made to APSPF Department for security guard services U/s. 40(a)(iib) of the Act. He ought to have considered that section 154 cannot be invoked in the case of the issues of debatable nature. 3. On the facts and in the circumstances of the case

ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE1(1), VIJAYAWADA

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallow payments made for supply of water and for payment made to APSPF Department for security guard services U/s. 40(a)(iib) of the Act. He ought to have considered that section 154 cannot be invoked in the case of the issues of debatable nature. 3. On the facts and in the circumstances of the case

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)

disallow payments made for supply of water and for payment made to APSPF Department for security guard services U/s. 40(a)(iib) of the Act. He ought to have considered that section 154 cannot be invoked in the case of the issues of debatable nature. 3. On the facts and in the circumstances of the case