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 of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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 of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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 of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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 of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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 of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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 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 of expenditure by the Ld. AO amounting to Rs. 71,14,092/- spent by Director

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 r.w Rule 8D of Rs. 15,42,448/-. 11. Accordingly, the AO vide his order passed under section 143(3) r.w.s 144B of the Act, dated 20/09/2021, determined the income of the assessee company at Rs. 50,14,81,765/-. 12. Aggrieved, the assessee company carried the matter in appeal before the CIT(A), who after

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 r.w Rule 8D of Rs. 15,42,448/-. 11. Accordingly, the AO vide his order passed under section 143(3) r.w.s 144B of the Act, dated 20/09/2021, determined the income of the assessee company at Rs. 50,14,81,765/-. 12. Aggrieved, the assessee company carried the matter in appeal before the CIT(A), who after

M/S MAATHA FINANCIERS,,PALAKOL vs. THE ITO,, PALAKOL

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Blem/S. Maatha Financiers, Vs. Ito, Ward-1, 13-5-42, Canal Road, Palakol. Palakol, W.G. District. Pan No. Aalfm 2319 K (Appellant) (Respondent)

disallowance under section 40(a)(ia) as the assessee failed to comply with the provisions of section 194A of the Act. In the assessment order, the Assessing Officer noted that the assessee paid interest on unsecured loans of Rs. 15,60,164/- in 58

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1),, VISAKHAPATNAM vs. SARITA SYNTHETICS & INDUSTRIES LIMITED,, RAJAM

In the result, appeal of the revenue is dismissed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.488 & 489/Viz/2018 (ननधधारण वर्ा/ Assessment Years: 2012-13 & 2013-2014 Respectively) Dy.Commissioner Of Income Tax, Vs. M/S Sarita Synthetics & Circle-4(1) Industries Ltd. Visakhapatnam D.No.11-8-120 Anthakapalli Village Srikakulam [Pan :Aadcs4025R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Smt. Suman Malik, Dr प्रत्यधथी की ओर से/ Respondent By : None

58,913 for the A.Y.2012- 13 and Rs.1,05,85,358/- for the A.Y.2013-14. During the assessment proceedings, the AO made the following additions to the income / loss returned as under : A.Y.2012-13 (i) Disallowance of expenditure u/s 40(a)(ia) Rs.1,23,500 (ii) Non confirmation from creditor Rs.39,155 (iii) Expenditure in relation to exempt income Rs.2

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1),, VISAKHAPATNAM vs. SARITA SYNTHETICS & INDUSTRIES LIMITED, , SRIKAKULAM

In the result, appeal of the revenue is dismissed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.488 & 489/Viz/2018 (ननधधारण वर्ा/ Assessment Years: 2012-13 & 2013-2014 Respectively) Dy.Commissioner Of Income Tax, Vs. M/S Sarita Synthetics & Circle-4(1) Industries Ltd. Visakhapatnam D.No.11-8-120 Anthakapalli Village Srikakulam [Pan :Aadcs4025R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Smt. Suman Malik, Dr प्रत्यधथी की ओर से/ Respondent By : None

58,913 for the A.Y.2012- 13 and Rs.1,05,85,358/- for the A.Y.2013-14. During the assessment proceedings, the AO made the following additions to the income / loss returned as under : A.Y.2012-13 (i) Disallowance of expenditure u/s 40(a)(ia) Rs.1,23,500 (ii) Non confirmation from creditor Rs.39,155 (iii) Expenditure in relation to exempt income Rs.2

PANDALAPAKA PRIMARY AGRICULTURAL CO-OP CREDIT SOCIETY LTD,EAST GODAVARI vs. INCOME-TAX OFFICER-WARD-1, KAKINADA

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.437 & 438/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19 & 2020-21) Pandalapaka Primary Agricultural V. Income Tax Officer – Ward – 1 Income Tax Office Co-Op Credit Society Ltd., 3Rd Floor, Deepthi Towers 5-28/1, Pandalapaka Main Road, Kakinada – 533001 Biccavole Mandal – 533345 Andhra Pradesh [Pan: Aabap2382G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

58,02,237/-. With respect to the disallowances of Rs. 49,53,669/- claimed as deduction under section 80P of the Act the Ld. CIT(A) confirmed

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:

disallow the expenditure, due to non deduction of tax at source, even in a situation in which corresponding income is brought to tax in the hands of the recipient. The scheme of Section 40(a)(ia), as we see it, is aimed at ensuring that an expenditure should not be allowed as deduction in the hands of an assessee

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.

Section 2(24)(x) is found to be valid and proper in fact and law. Considering the totality of the facts and circumstances of the case, the disallowance of Rs. 2,32,202/- on the above account is confirmed and the ground no. 1 of the appellant is dismissed. 5.4 Ground No. 3 relates to addition

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, 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

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