VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, , VISAKHAPTNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

THE VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASST. CIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

VISAKHAPATNAM PORT AUTHORITY, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

70 provisions of section 43B of the Act, interest payable on loans borrowed from any Financial Institutions and Banks only are covered. He therefore pleaded that the interest payable on the loans obtained from Government of India are not covered under the provisions and accordingly no disallowance can be made. The Ld. AR relied on the case

INCOME TAX OFFICER, WRD-1, BHIMAVARAM vs. YENDANGANDHI LARGE SIZED CO-OPERATIVE SOCIETY LTD, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.243/Viz/2022 (निर्धारण वर्ा / Assessment Year : 2018-19) Income Tax Officer Vs. M/S Yendagandhi Large Sized Ward-1 Co-Operative Society Ltd. Bhimavaram D.No.4-13, K.K.Road Yendagandi, West Godavari Dist [Pan : Aacat0967G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Cross Objection No.01/Viz/2023 (Arising Out Of I.T.A.No.243/Viz/2022) (निर्धारण वर्ा / Assessment Year : 2018-19) M/S Yendagandhi Large Sized Co- Income Tax Officer Operative Society Ltd. Ward-1 D.No.4-13, K.K.Road Bhimavaram Yendagandi, West Godavari Dist [Pan : Aacat0967G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Assessee By : Shri G.V.N.Hari, Ar Revenue By : Shri Madhukar Aves, Dr सुिवधई की तधरीख / Date Of Hearing 10.10.2023 : घोर्णध की तधरीख/Date Of Pronouncement : 22.11.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: This Appeal Is Filed By The Revenue Against The Order Of Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless

3 are related to disallowance of deduction claimed u/s 80P(2)(a)(i) of the Act. The Ld.DR submitted that the Ld.CIT(A) is not justified in deleting the addition of Rs.2,59,54,906/- and Rs.3,70,365/- made by the AO on account of disallowance of deduction claimed by the assessee u/s 80P(2)(a)(i). The Ld.CIT

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)

3) of the Income Tax Act, 1961 (in short ‘Act’) dated 29.12.2017. 17. Brief facts of the case are that, 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. The case was selected for scrutiny under CASS and notice 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)

3) of the Income Tax Act, 1961 (in short ‘Act’) dated 29.12.2017. 17. Brief facts of the case are that, 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. The case was selected for scrutiny under CASS and notice 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)

3) of the Income Tax Act, 1961 (in short ‘Act’) dated 29.12.2017. 17. Brief facts of the case are that, 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. The case was selected for scrutiny under CASS and notice under section

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM vs. PRATHYUSHA GLOBAL TRADE PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal filed by the Revenue is partly allowed and the petition filed by assessee under Rule 27 of the ITAT Rules is dismissed

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

70 ponds which in our opinion are capital in nature and was used as a tool for the business of the assessee. We therefore are of the considered view that this expenditure constitutes plant and machinery of the assessee and hence the Ld. AO has is correct in allowing the depreciation @ 15% of expenditure incurred by the assessee thereby disallowing

INCOMETAX OFFICER, WARD-3(1), VISAKHAPATNAM vs. SURENDRA NATH GUBBALA, VISAKHAPATNAM

Bench: Us:

section 48(i) of the Act and deleted the disallowance made by the A.O. For the sake of clarity, we deem it apposite to cull out the observations of the CIT(A), as under: “5. Findings & Decision: 5.1 I have gone through the Assessment Order, Statement of Facts and Grounds of Appeal filed by the appellant and the written submissions

ARRDY ENGINEERING INNOVATIONS PVT LTD,ODISHA vs. ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-1(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.307 & 308/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2012-13 & 2013-14) M/S. Arrdy Engineering Innovations (P.) Ltd., V. Asst. Cit – Circle – 1(1) Bb-8 Area 7 & 8 Income Tax Office Civil Township, Rourkela – 769004 Direct Tax Building, Mvp Colony Visakhapatnam – 530017 Odisha Andhra Pradesh [Pan: Aabca4800A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

3,45,70,738 under Page No. 2 I.T.A.Nos.307 & 308/VIZ/2023 M/s. Arrdy Engineering Innovations (P.) Ltd., section 35(2AB) of the Act. Assessing Officer also noticed that assessee has received a grant of Rs.50,00,000/- from DSIR during the year. Therefore, he concluded that assessee is eligible for deduction on the balance expenditure

AARDY ENGINEERING INNOVATION PVT LTD,ODISHA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.307 & 308/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2012-13 & 2013-14) M/S. Arrdy Engineering Innovations (P.) Ltd., V. Asst. Cit – Circle – 1(1) Bb-8 Area 7 & 8 Income Tax Office Civil Township, Rourkela – 769004 Direct Tax Building, Mvp Colony Visakhapatnam – 530017 Odisha Andhra Pradesh [Pan: Aabca4800A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

3,45,70,738 under Page No. 2 I.T.A.Nos.307 & 308/VIZ/2023 M/s. Arrdy Engineering Innovations (P.) Ltd., section 35(2AB) of the Act. Assessing Officer also noticed that assessee has received a grant of Rs.50,00,000/- from DSIR during the year. Therefore, he concluded that assessee is eligible for deduction on the balance expenditure

SRI TIRUMALA ESTATES AND FARMLANDS,VISAKHAPATNAM vs. ACIT, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

disallowance of 20% of the said expenditure amounted to Rs. 70,44,110/-. 3. The assessment has been subsequently reopened under Section