AUDREY BERNICE ROY,VISAKHAPATNAM vs. INCOME TAX OFFICER, VISAKHAPATNAM

Bench: Shri Ravish Sood, Hon’Ble

House Property: Rs. 1,35,000/-; (ii) Income from Salary: Rs. 12,05,509/-; and (iii) Income from Other Sources: Rs. NIL. Thereafter the AO/CPC, Bengaluru vide an intimation issued under section 143

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

Section 143(1)\nof the Act, and all the more those for AY 2020-21 and AY 2021-22 had\n38\nITA No.314 & 206/Viz/2025\nITA No. 205/Viz/2024\nNord Anglia Education Infrastructure\nPrivate Limited vs. DCIT I\nbeen accepted after being subjected to scrutiny assessment under\nSection 143(3) of the Act, therefore, as per the principle of consistency

VENKATA RAMANA GODA,VISAKHAPATNAM vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

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.489/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Venkata Ramana Goda, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Circle-3(1), Pan: Abzpg3216A Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 17/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 08/03/2025. The 2 Venkata Ramana Goda Vs. Acit

property, thus, in the absence of the requisite details, held the entire amount of the sale consideration of Rs. 61.60 lakhs (supra) as his income under the head “Short term capital gain” (STCG) and added the same to his income. 6 Venkata Ramana Goda vs. ACIT 6. Accordingly, the AO, after making the aforementioned additions, vide his order passed under

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

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

VIKRAM BRAHMENDRA SATYAJIT MULPURI,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-3(1), VIJAYAWADA

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.534/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Vikram Brahmendra Satyajit Vs. Income Tax Officer, Mulpuri, Ward-3(1), Krishna District. Vijayawada. Pan: Aonpm1893G (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 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm:

property (as per SRO, Patamata): Rs.56,58,000/-, but not filed his return of income, initiated proceedings under section 148A of the Act. Thereafter, 3 Vikram Brahmendra Satyajit Mulpuri vs. ITO the AO issued notice under section 148 of the Act, dated 23/03/2024. In compliance, the assessee filed his return of income in response to the notice under section

GOWTHAM RESIDENTIAL JUNIOR COLLEGE,VIJAYAWADA vs. ACIT, CENTRAL CIRCLE, VIJAYAWADA

In the result, appeals of the assessee are allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.25 & 26/Viz/2022 (निर्धारण वर्ा/ Assessment Years: 2017-18 & 2013-14) Gowtham Residential Junior College V. Asst. Cit-Central Circle Vijayawada 1-87, Gudavalli Village Gudavalli, Vijayawada – 521104 Andhra Pradesh [Pan: Aaefg4399L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 28(i),of the Income – tax Act, 1961- Income from house property- chargeable as (Business income v. Property Income) – Assessment years 2004-05, 2005-06, 2007-08 and 2008-09 – High Court by impugned order held that where assessee was not engaged in any business activity, rental income earned from letting out commercial complex would be assessed as income

GOWTHAM RESIDENTIAL JUNIOR COLLEGE,VIJAYAWADA vs. ACIT, CENTRAL CIRCLE, VIJAYAWADA

In the result, appeals of the assessee are allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.25 & 26/Viz/2022 (निर्धारण वर्ा/ Assessment Years: 2017-18 & 2013-14) Gowtham Residential Junior College V. Asst. Cit-Central Circle Vijayawada 1-87, Gudavalli Village Gudavalli, Vijayawada – 521104 Andhra Pradesh [Pan: Aaefg4399L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 28(i),of the Income – tax Act, 1961- Income from house property- chargeable as (Business income v. Property Income) – Assessment years 2004-05, 2005-06, 2007-08 and 2008-09 – High Court by impugned order held that where assessee was not engaged in any business activity, rental income earned from letting out commercial complex would be assessed as income

TATIPARTI SATYANARAYANA,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.357/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2022-23) Tatiparti Satyanarayana V. Ito – Ward – 1(1) D.No. 47-15-10, Shop No. 201A Income Tax Office V.R.C. Complex, Dwaraka Nagar Pratyakshakar Bhavan Visakhapatnam – 530016 Mvp Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan: Acgpt5353F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

house property 4. Any other ground that may be urged at the time of appeal hearing.” 5. Ground Nos. 1 and 4 are general in nature and needs no adjudication. 6. Ground Nos. 2 and 3 relates to holding the adjustment by the CPC, Bangalore for Rs.18,52,306/- made by the CPC in the intimation under section 143

INCOME TAX OFFICER, WARD 3(3) , VISAKHAPATNAM vs. MEENA TANGUDU, VISAKHAPATNAM

In the result, appeal of the revenue is partly allowed

property\", other than\nthe new asset, the amount of capital gain arising from the transfer of the\noriginal asset not charged under section 45 on the basis of the cost of such\nnew asset as provided in clause (a), or, as the case may be, clause (b), of\nsub-section (1), shall be deemed to be income chargeable under

SITA RAMA RAJU SAGI,BHIMAVARAM vs. ITO WARD 1 BHIMAVARAM, BHIMAVARAM

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.154/Viz/2025 (धनिाारण िर्ा / Assessment Year : 2020-21) Sita Rama Raju Sagi, Vs. Income Tax Officer, Bhimavaram – 534202. Ward-1, Pan: Egapa3925J Bhimavaram. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलार्थी की ओर से/ Assessee By : Mrs. Hema Latha K, Ca प्रत्यार्थी की ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनिाई की तारीख / Date Of Hearing : 30/04/2025 घोर्णा की तारीख/Date Of : 20/05/2025 Pronouncement O R D E R

143(3) r.w.s 144B of the Act as erroneous insofar as prejudicial to the interest of the revenue. He therefore issued show cause notices on 13/09/2024 and 29/10/2024 through ITBA asking the assessee to furnish any submissions / representations in the revision of income by denying the benefit of carry forward of house properly loss and denying the claim

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA vs. SIVA JYOTHI PALAM, VIJAYAWADA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.268/Viz/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Assistant Commissioner Of Vs. Siva Jyothi Palam, Income Tax, Vijayawada. Circle-1(1), Pan: Bksps2554L Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) C.O. No. 04/Viz/2024 (In आयकर अपील सं./ I.T.A. No.268/Viz/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Siva Jyothi Palam, Vs. Assistant Commissioner Of Vijayawada. Income Tax, Pan: Bksps2554L Circle-1(1), Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri C. Subrahmanyam, Ar ""याथ" क" ओर से / Respondent By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 01/10/2024 घोषणा क" तारीख/Date Of : 09/10/2024 Pronouncement O R D E R

house property at Chennai for a consideration of Rs. 6,06,10,000/- and claimed deduction U/s. 54F of the Act. After considering the submissions of the assessee as well as the material available on record, the Ld. AO completed the assessment U/s. 143(3) of the Act and disallowed the assessee’s claim of exemption

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

section 2(47)(v) of the Act r.w.s. 53A of the Transfer of Property Act. Thus, once the parties have agreed to the consideration in terms of money, then execution of JDA along with the irrevocable GPA amounts to transfer of the land in favour of the developer. The learned DR has relied upon the impugned order of the learned

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

section 2(47)(v) of the Act r.w.s. 53A of the Transfer of Property Act. Thus, once the parties have agreed to the consideration in terms of money, then execution of JDA along with the irrevocable GPA amounts to transfer of the land in favour of the developer. The learned DR has relied upon the impugned order of the learned

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

section 2(47)(v) of the Act r.w.s. 53A of the Transfer of Property Act. Thus, once the parties have agreed to the consideration in terms of money, then execution of JDA along with the irrevocable GPA amounts to transfer of the land in favour of the developer. The learned DR has relied upon the impugned order of the learned

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

section 2(47)(v) of the Act r.w.s. 53A of the Transfer of Property Act. Thus, once the parties have agreed to the consideration in terms of money, then execution of JDA along with the irrevocable GPA amounts to transfer of the land in favour of the developer. The learned DR has relied upon the impugned order of the learned