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)

disallowance of Rs. 14,72,27,627/-. In submissions made by the Ld. AR we find that similar contributions have also made with respect to pension payments made during the year. Further, we also accept the contention of the Ld. AR that the actuarial valuation as on 31/3/2011 works out to Rs. 1,896.07 Crs and the assessee

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)

disallowance of Rs. 14,72,27,627/-. In submissions made by the Ld. AR we find that similar contributions have also made with respect to pension payments made during the year. Further, we also accept the contention of the Ld. AR that the actuarial valuation as on 31/3/2011 works out to Rs. 1,896.07 Crs and the assessee

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)

disallowance of Rs. 14,72,27,627/-. In submissions made by the Ld. AR we find that similar contributions have also made with respect to pension payments made during the year. Further, we also accept the contention of the Ld. AR that the actuarial valuation as on 31/3/2011 works out to Rs. 1,896.07 Crs and the assessee

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)

disallowance of Rs. 14,72,27,627/-. In submissions made by the Ld. AR we find that similar contributions have also made with respect to pension payments made during the year. Further, we also accept the contention of the Ld. AR that the actuarial valuation as on 31/3/2011 works out to Rs. 1,896.07 Crs and the assessee

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)

disallowance of Rs. 14,72,27,627/-. In submissions made by the Ld. AR we find that similar contributions have also made with respect to pension payments made during the year. Further, we also accept the contention of the Ld. AR that the actuarial valuation as on 31/3/2011 works out to Rs. 1,896.07 Crs and the assessee

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

72 Taxmann.com 192 P& H), wherein it was held that deduction on interest expenditure on borrowed funds is not allowable in view of the proviso to section u/s 36(1)(iii), when the corresponding assets were not put to use. 7. The Ld. CIT(A) is not justified in allowing relief towards proportionate disallowance

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

72 Taxmann.com 192 P& H), wherein it was held that deduction on interest expenditure on borrowed funds is not allowable in view of the proviso to section u/s 36(1)(iii), when the corresponding assets were not put to use. 7. The Ld. CIT(A) is not justified in allowing relief towards proportionate disallowance

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

72 Taxmann.com 192 P& H), wherein it was held that deduction on interest expenditure on borrowed funds is not allowable in view of the proviso to section u/s 36(1)(iii), when the corresponding assets were not put to use. 7. The Ld. CIT(A) is not justified in allowing relief towards proportionate disallowance

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

72 Taxmann.com 192 P& H), wherein it was held that deduction on interest expenditure on borrowed funds is not allowable in view of the proviso to section u/s 36(1)(iii), when the corresponding assets were not put to use. 7. The Ld. CIT(A) is not justified in allowing relief towards proportionate disallowance

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

72 Taxmann.com 192 P& H), wherein it was held that deduction on interest expenditure on borrowed funds is not allowable in view of the proviso to section u/s 36(1)(iii), when the corresponding assets were not put to use. 7. The Ld. CIT(A) is not justified in allowing relief towards proportionate disallowance

ASSISTANT COMMISSIONER OF INCOME TAX,EXEMPTION CIR, VIJAYAWADA vs. SRI KOUNDINYA EDUCATIONAL SOCIETY, RAJAHMUNDRY

72,000/-\n2\nDisallowance under section 40(a)(ia) of the Act\nRs.37,95,902/-\n3\nDisallowances of interest\nRs.3,76,800/-\n4\nLd. AO also denied the exemption claimed by the assessee under section 11 of the Act.\nPage No. 3\nI.T.A.No.62/VIZ/2024\nC.O. No. 6/VIZ/2024\nSri Koundinya Educational Society --\n4. On being aggrieved by the order

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. VENKATRAMA POULTRIES PVT. LTD, GUNTUR

1.\nThe order of the Ld.ClT(A) is erroneous both on the facts and in law.\n2.\nThe L.d. CIT(A) ought to have upheld the working of average price\nper egg at Rs 3.83, as done by the AO in the assessment order. The CIT(A)\nerred in directing the AO to recompute the average price

SANTOSH AGRAWAL,CHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRLCE-1, VISAKHAPATNAM

disallowing the long-term capital gains claimed as\nexemption under section 10(38) of the Act and thereby we allow the ground\nraised by the assessee.\n31. In the result, appeal of the assessee is allowed.\nITA No. 150/VIZ/2025 (A.Y. 2006-07) – (APPEAL RELATING TO SANTOSH AGRAWAL).\n32. Assessee has raised following grounds of appeal: -\n\"1. On the facts

SANDHYA AQUA EXPORTS PVT LTD,VISAKHAPATNAM vs. DEPUTY COMMISSIONER/ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 4(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. 203/Viz/2021 (निर्धारण वर्ा/Assessment Year : 2019-20) Sandhya Aqua Exports Pvt. Ltd.Mig- Vs. Dy.Commissioner / 25 A, Lawsons Bay Colony Asst.Commissioner Of Visakhapatnam Income Tax, Circle-4(1) Visakhapatnam [Pan : Aajcs2286C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : None प्रत्यधथी की ओर से / Respondent By : Shri Spg Mudaliar, Dr सुिवधई की तधरीख / Date Of Hearing : 03.02.2022 16.02.2022 घोर्णध की तधरीख/Date Of Pronouncement : आदेश /O R D E R Per Shri Duvvuru Rl Reddy:

72,37,170/-. As per the intimation u/s 143(1) of the Income Tax Act, 1961 (in short ‘Act’), passed by the ADIT, Centralized Processing Center (CPC), Bangalore dated 01.05.2020 made disallowance of expenses in relation to employees contribution to PF and ESI to the tune of Rs.7,56,158/- and raised the demand accordingly. 3. On being aggrieved

ASHOK KUMAR AGRAWAL,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

disallowing the long-term capital gains claimed as\nexemption under section 10(38) of the Act and thereby we allow the ground\nraised by the assessee.\n\n31. In the result, appeal of the assessee is allowed.\n\nITA No. 150/VIZ/2025 (A.Y. 2006-07) – (APPEAL RELATING TO SANTOSH AGRAWAL).\n\n32. Assessee has raised following grounds of appeal

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)

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 43B of the Act. In addition, Assessing

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)

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 43B of the Act. In addition, Assessing

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)

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 43B of the Act. In addition, Assessing

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)

disallowance of Rs. 14,72,27,627/-. In submissions made by the Ld. AR we find that similar contributions have also made with respect to pension payments made during the year. Further, we also 48 accept the contention of the Ld. AR that the actuarial valuation as on 31/3/2011 works out to Rs. 1,896.07 Crs and the assessee