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 wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances

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 wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances

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 wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances

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 wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances

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 wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances

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 wherein the additions were made based on the impounded material shall be mutatis mutandis applies to this ground. Accordingly, this ground raised by the revenue is dismissed. 57. Ground Nos. 9, 10 & 11 is with respect to the disallowances

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 Rs. 15,42,488/- Private Limited vs. DCIT made by the AO by an amount of Rs. 20,585/-, i.e., the exempt income earned by the assessee company during the subject year. 20. Per Contra, Shri. Karanjot Singh Khurana, Advocate – Ld. Authorized Representative (for short, “AR”) for the assessee company, at the threshold of hearing

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 Rs. 15,42,488/- Private Limited vs. DCIT made by the AO by an amount of Rs. 20,585/-, i.e., the exempt income earned by the assessee company during the subject year. 20. Per Contra, Shri. Karanjot Singh Khurana, Advocate – Ld. Authorized Representative (for short, “AR”) for the assessee company, at the threshold of hearing

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)

section 43B of the Act. In addition, Assessing Officer also further disallowed Rs. 6,59,500/- as confirmation of the closing balance of the creditor namely M/s. Electro Mech Engineering Services was not proved by the assessee. The Assessing Officer also disallowed a sum ofRs.1,57

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)

section 43B of the Act. In addition, Assessing Officer also further disallowed Rs. 6,59,500/- as confirmation of the closing balance of the creditor namely M/s. Electro Mech Engineering Services was not proved by the assessee. The Assessing Officer also disallowed a sum ofRs.1,57

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)

section 43B of the Act. In addition, Assessing Officer also further disallowed Rs. 6,59,500/- as confirmation of the closing balance of the creditor namely M/s. Electro Mech Engineering Services was not proved by the assessee. The Assessing Officer also disallowed a sum ofRs.1,57

JAIN BABULAL CHAMPATLAL,VIJAYAWADA vs. INCOME TAX OFFICER, WARD 2(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are 9

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.394 & 395/Viz/2025 (निर्धारणवर्ा/ Assessment Year:2017-18) Vs. Jain Babulal Champatlal Income Tax Officer – Ward – 2(1) Cr Building, 1St Floor Annex 40-1-155, Lgf Mg Road, Vijayawada – 520002 Ripples Mall, M.G. Road Andhra Pradesh Vijayawada-520010 Andhra Pradesh [Pan:Aefpc1220F]

section 57 of the Act, accordingly, disallowed the same and added back to the total income of the assessee. While

JAIN BABULAL CHAMPATLAL,VIJAYAWADA vs. INCOME TAX OFFICER, WARD 2(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are 9

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.394 & 395/Viz/2025 (निर्धारणवर्ा/ Assessment Year:2017-18) Vs. Jain Babulal Champatlal Income Tax Officer – Ward – 2(1) Cr Building, 1St Floor Annex 40-1-155, Lgf Mg Road, Vijayawada – 520002 Ripples Mall, M.G. Road Andhra Pradesh Vijayawada-520010 Andhra Pradesh [Pan:Aefpc1220F]

section 57 of the Act, accordingly, disallowed the same and added back to the total income of the assessee. While

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

disallowance under Section 14A of Rs. 15,42,488/-\n29\nITA No.314 & 206/Viz/2025\nITA No. 205/Viz/2024\nNord Anglia Education Infrastructure\nPrivate Limited vs. DCITT\nmade by the AO by an amount of Rs. 20,585/-, i.e., the exempt income\nearned by the assessee company during the subject year.\n20. Per Contra, Shri. Karanjot Singh Khurana, Advocate Ld.\nAuthorized Representative

MOHSIN ENTERPRISES PRIVATE LTD,VISAKHAPATNAM vs. INCOME TAX OFFICR, WARD-3(3), VISAKHAPATNAM

In the result, appeal filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

section 57. The reason which found favour both with the Assessing Officer and the Tribunal was that the investment was not for the purpose of earning dividend. It could not be followed as to how can it be said that earning of dividend can be the sole motive or the sole source for the purpose of making income from other

DEVI SEA FOODS LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE -3(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.156/Viz/2022 (निर्धारण वर्ा / Assessment Year : 2018-19) M/S Devi Sea Foods Limited Vs. Deputy Commissioner Of 50-1-51/1, A.S.R.Nagar Income Tax Seethammadhara Circle-3(I) Visakhapatnam Visakhapatnam [Pan : Aabcd0248B] अपीलधथी की ओर से/ Appellant By : Shri D.Anand, Ar प्रत्यधथी की ओर से / Respondent By : Shri M.N.Murthy Naik, Cit(Dr) सुिवधई की तधरीख / Date Of Hearing : 01.12.2022 घोर्णध की तधरीख/Date Of Pronouncement : 16.12.2022 O R D E R Per Shri S.Balakrishnan:

disallowance as per Rule 8D of I.T.Rules, 1962. Aggrieved by the order passed by the AO based on the directions of the Ld.DRP, the assessee is in appeal before us and raised the following grounds : 1. The Final Assessment order incorporating Transfer Pricing adjustment passed by the learned Assessing Officer 4 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam

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 issues: (i) Amount of Rs. 34,57,48,140/- paid for water supplied by AP Irrigation & CAD (PW: AC&JWS/COD) Department (Now Water Resource Department) of Andhra Pradesh State Government. (ii) Amount of Rs. 35,94,33,899/- paid to APSPF Department of Andhra Pradesh State Government for provision

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)

section 40(a)(iib) of the Act on the following issues: (i) Amount of Rs. 34,57,48,140/- paid for water supplied by AP Irrigation & CAD (PW: AC&JWS/COD) Department (Now Water Resource Department) of Andhra Pradesh State Government. (ii) Amount of Rs. 35,94,33,899/- paid to APSPF Department of Andhra Pradesh State Government for provision