KONDA SRINIVASA REDDY,GUNTUR vs. INCOME TAX OFFICER, WARD-2(1), GUNTUR

In the result, all the 4 appeals of the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnanappeal No. Assessee Respondent A.Y 209/Viz/2024 Konda Srinivasa Income Tax Officer 2016-17 Reddy, Guntur, Ward 2(1) Pan:Aafhk9821E Guntur 216/Viz/2024 Veerareddy Gogula - Do - -Do- Guntur Pan:Byapg6481J - Do - 217/Viz/2024 Swarajyam -Do- Dontireddy Guntur Pan:Cmmpd3393K - Do - 218/Viz/2024 Vijaya Lakshmi -Do- Ravula, Guntur Pan:Baopr0163G

46 (Supreme Court) ii) Dy.CIT vs. Bharat Jasyantilal Patel (2023) 462 ITR 455 (Supreme Court) iii) Darshana Anand Damle vs. Dy.CIT (2023) 459 ITR 60 (Bom.) 7. Thus, the learned AR submitted that in all those judgements, it has been held that handing over of the possession under the JDA does not constitute transfer u/s 53A on transfer of property

VIJAYA LAKSHMI RAVULA,GUNTUR vs. INCOME TAX OFFICER, WARD-2(1), GUNTUR

In the result, all the 4 appeals of the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnanappeal No. Assessee Respondent A.Y 209/Viz/2024 Konda Srinivasa Income Tax Officer 2016-17 Reddy, Guntur, Ward 2(1) Pan:Aafhk9821E Guntur 216/Viz/2024 Veerareddy Gogula - Do - -Do- Guntur Pan:Byapg6481J - Do - 217/Viz/2024 Swarajyam -Do- Dontireddy Guntur Pan:Cmmpd3393K - Do - 218/Viz/2024 Vijaya Lakshmi -Do- Ravula, Guntur Pan:Baopr0163G

46 (Supreme Court) ii) Dy.CIT vs. Bharat Jasyantilal Patel (2023) 462 ITR 455 (Supreme Court) iii) Darshana Anand Damle vs. Dy.CIT (2023) 459 ITR 60 (Bom.) 7. Thus, the learned AR submitted that in all those judgements, it has been held that handing over of the possession under the JDA does not constitute transfer u/s 53A on transfer of property

VEERAREDDY GOGULA,GUNTUR vs. INCOME TAX OFFICER, WARD-2(1), GUNTUR

In the result, all the 4 appeals of the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnanappeal No. Assessee Respondent A.Y 209/Viz/2024 Konda Srinivasa Income Tax Officer 2016-17 Reddy, Guntur, Ward 2(1) Pan:Aafhk9821E Guntur 216/Viz/2024 Veerareddy Gogula - Do - -Do- Guntur Pan:Byapg6481J - Do - 217/Viz/2024 Swarajyam -Do- Dontireddy Guntur Pan:Cmmpd3393K - Do - 218/Viz/2024 Vijaya Lakshmi -Do- Ravula, Guntur Pan:Baopr0163G

46 (Supreme Court) ii) Dy.CIT vs. Bharat Jasyantilal Patel (2023) 462 ITR 455 (Supreme Court) iii) Darshana Anand Damle vs. Dy.CIT (2023) 459 ITR 60 (Bom.) 7. Thus, the learned AR submitted that in all those judgements, it has been held that handing over of the possession under the JDA does not constitute transfer u/s 53A on transfer of property

SWARAJYAM DONTIREDDY,GUNTUR vs. INCOME TAX OFFICER, WARD-2(1), GUNTUR

In the result, all the 4 appeals of the assessee are allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnanappeal No. Assessee Respondent A.Y 209/Viz/2024 Konda Srinivasa Income Tax Officer 2016-17 Reddy, Guntur, Ward 2(1) Pan:Aafhk9821E Guntur 216/Viz/2024 Veerareddy Gogula - Do - -Do- Guntur Pan:Byapg6481J - Do - 217/Viz/2024 Swarajyam -Do- Dontireddy Guntur Pan:Cmmpd3393K - Do - 218/Viz/2024 Vijaya Lakshmi -Do- Ravula, Guntur Pan:Baopr0163G

46 (Supreme Court) ii) Dy.CIT vs. Bharat Jasyantilal Patel (2023) 462 ITR 455 (Supreme Court) iii) Darshana Anand Damle vs. Dy.CIT (2023) 459 ITR 60 (Bom.) 7. Thus, the learned AR submitted that in all those judgements, it has been held that handing over of the possession under the JDA does not constitute transfer u/s 53A on transfer of property

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

Bench: Us:

10. Having heard learned advocates for the respective parties and considering the impugned order as well as the facts and the findings arrived at by the Tribunal, it is clear the Apex Court in the case of V.S.M.R. Jagdadishchandran (supra) has dismissed the appeal in the facts of the said case on the ground that the mortgage was created

AS RAJA SONS ENTERPRISES PVT LTD,VISAKHAPATNAM 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.No.379/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19) A.S. Raja Sons Enterprises (P.) Ltd., V. Asst. Cit – Circle – 1(1) Income Tax Office D.No. 10-5-11/5 Pratyakshakar Bhavan Care Hospital, Waltair Main Road Mvp Double Road Visakhapatnam – 530002 Visakhapatnam - 530017 Andhra Pradesh Andhra Pradesh [Pan: Aabca4796M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

10-5-11/5 Pratyakshakar Bhavan Care Hospital, Waltair Main Road MVP double Road Visakhapatnam – 530002 Visakhapatnam - 530017 Andhra Pradesh Andhra Pradesh [PAN: AABCA4796M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented by : Shri G.V.N. Hari, AR राजस्वका प्रतततितित्व/ Department Represented by : Dr.Satyasai Rath, CIT(DR) सुिवाई समाप्त होिे की ततति/ Date of Conclusion of Hearing : 21.10.2024 घोर्णध की

ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-1(1), GUNTUR vs. ANDHRA PRADESH STATE COUNCIL OF HIGHER EDUCATION , NEELADRI TOWERS

In the result, appeal filed by the revenue is dismissed

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.376 & 377/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19 & 2019-20) Asst. Cit– Circle – 1(1) V. Andhra Pradesh State Council 2Nd Floor, Standard House Of Higher Education Atmakur Village Nagarampalem – 522004 Mangalagiri-522503 Guntur, Andhra Pradesh Andhra Pradesh [Pan: Aamfa3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

House of Higher Education Atmakur Village Nagarampalem – 522004 Mangalagiri-522503 Guntur, Andhra Pradesh Andhra Pradesh [PAN: AAMFA3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented by : Shri GVN Hari, AR Dr. Aparna Villuri, Sr. AR राजस्व का प्रतततितित्व/ Department Represented by : सुिवाई समाप्त होिे की ततति/ Date of Conclusion of Hearing : 20.11.2024 घोर्णध की तधरीख/Date of Pronouncement

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR vs. ANDHRA PRADESH STATE COUNCIL OF HIGHER EDUCATION , NEELADHRI TOWERS

In the result, appeal filed by the revenue is dismissed

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.376 & 377/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19 & 2019-20) Asst. Cit– Circle – 1(1) V. Andhra Pradesh State Council 2Nd Floor, Standard House Of Higher Education Atmakur Village Nagarampalem – 522004 Mangalagiri-522503 Guntur, Andhra Pradesh Andhra Pradesh [Pan: Aamfa3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

House of Higher Education Atmakur Village Nagarampalem – 522004 Mangalagiri-522503 Guntur, Andhra Pradesh Andhra Pradesh [PAN: AAMFA3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented by : Shri GVN Hari, AR Dr. Aparna Villuri, Sr. AR राजस्व का प्रतततितित्व/ Department Represented by : सुिवाई समाप्त होिे की ततति/ Date of Conclusion of Hearing : 20.11.2024 घोर्णध की तधरीख/Date of Pronouncement

KANCHAN LALWANI,VIZIANAGARAM vs. INCOME TAX OFFICER, WARD-1, VIZIANAGARAM

In the result, the appeal filed by the assessee is allowed

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

46,875/- + Rs.39,73,500/-]. Further, the Assessing Officer 5 noted in the assessment order the income tax returns filed by the assessee from the financial year 2001-2002 to 2006-2007, 2008- 2009 to 2020-2021 and her admitted income totalling to Rs.79,88,483/- which was tabulated by the Assessing Officer at pages

SATYANARAYANA KODURU,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-1, GUDIWADA

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.491/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Satyanarayana Koduru, Vs. Income Tax Officer, Krishna District. Ward-1, Pan:Altpk1048C Gudiwada. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

property of Rs.59,84,000/-; (ii) addition under section 69 of the Act in respect of the registration charges and stamp duty of Rs.4,48,700/-; (iii) addition under section 69A of the Act of unexplained cash deposits in bank account: Rs.32,30,000/-; (iv) addition of undisclosed salary received from NHAI: Rs.17,62,155/-; (v) 4 Satyanarayana Koduru

THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. NALLAMILLI SRIDEVI,, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

THE ASSISTANT COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. VITTALAM NATARAJ PRASAD, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. VITTALAM NATARAJ PRASAD, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION),, VISAKHAPATNAM vs. NALLAMILLI SRIDEVI,, TIRUPATI

In the result, Cross Objection raised by the assessee is dismissed

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

section we find that any return filed u/s. 139 or in response to a notice U/s. 142(1) of the Act can be selected for a scrutiny within six months from the end of the assessment year in which the return was filed by the assessee. Therefore, the issuance of notice U/s. 143(2) dated 24/1/2016

DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. SRI NARASIMHARAJU KANUMURI, VISAKHAPATNAM

In the result, the appeal filed by the revenue in ITA No

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.267/Viz/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Deputy Commissioner Of Vs. Sri Narasimharaju Income Tax, Kanumuri, Visakhapatnam. Visakhapatnam. Pan: Aerpk2717F (Appellant) (Respondent)

House Property in addition to agricultural income of Rs.7,94,923/-. Subsequently the return was selected for Complete Scrutiny under CASS and the AO completed the assessment u/s 143(3) and determining total assessed income of Rs.4,31,46,200/- by taking Rs.4,17,00,000/- towards income u/s 69A of the Act, 1961. The appellant preferred an appeal against

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

properties (assets). Accordingly, the AO worked out the unexplained investment made by the assessee during the subject year at Rs. 21,35,549/-, as under: Gattula Lakshmi Madhavi vs. ACIT 10. Thereafter, the AO vide his order under section 147 of the Act, dated 27/03/2023, determined the income of the assessee at Rs. 36,38,936/-. Also, the AO while

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

properties (assets). Accordingly, the AO worked out the unexplained investment made by the assessee during the subject year at Rs. 21,35,549/-, as under: Gattula Lakshmi Madhavi vs. ACIT 10. Thereafter, the AO vide his order under section 147 of the Act, dated 27/03/2023, determined the income of the assessee at Rs. 36,38,936/-. Also, the AO while

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

properties (assets). Accordingly, the AO worked out the unexplained investment made by the assessee during the subject year at Rs. 21,35,549/-, as under: Gattula Lakshmi Madhavi vs. ACIT 10. Thereafter, the AO vide his order under section 147 of the Act, dated 27/03/2023, determined the income of the assessee at Rs. 36,38,936/-. Also, the AO while