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

14A r.w Rule 8D of Rs.\n15,42,448/-.\n11. Accordingly, the AO vide his order passed under section 143(3)\nr.w.s 144B of the Act, dated 20/09/2021, determined the income of the\nassessee company at Rs. 50,14,81,765/-.\n12. Aggrieved, the assessee company carried the matter in appeal\nbefore the CIT(A), who after deliberating at length

ATR WAREHOUSING PRIVATE LIMITED,VISAKHAPATNAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VISAKHAPATNAM

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

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

property, other sources and agricultural income from warehousing filed its return of income for the AY 2014-15 on 30/11/2014 declaring total income of Rs. NIL (Loss of Rs. 2,83,99,853/-). The main source of business income is license fee collected from the tenants for the ware housing godowns at various places viz., Visakhapatnam, Kakinada and Hyderabad

ATR WAREHOUSING PRIVATE LIMITED .,VISAKHAPATNAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VISAKHAPATNAM

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

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

property, other sources and agricultural income from warehousing filed its return of income for the AY 2014-15 on 30/11/2014 declaring total income of Rs. NIL (Loss of Rs. 2,83,99,853/-). The main source of business income is license fee collected from the tenants for the ware housing godowns at various places viz., Visakhapatnam, Kakinada and Hyderabad

ATR WAREHOUSING PRIVATE LIMITED,VISAKHAPATNAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VISAKHAPATNAM

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

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

property, other sources and agricultural income from warehousing filed its return of income for the AY 2014-15 on 30/11/2014 declaring total income of Rs. NIL (Loss of Rs. 2,83,99,853/-). The main source of business income is license fee collected from the tenants for the ware housing godowns at various places viz., Visakhapatnam, Kakinada and Hyderabad

ATR WAREHOUSING PRIVATE LIMITED,VISAKHAPATNAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, , VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed

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

housing godowns at various places viz., Visakhapatnam, Kakinada and Hyderabad. Sri AT Rayudu and Sri A. Avnash are the Directors of the assessee-company who hold 45% each of the share- holding in the company. The case was selected for scrutiny under CASS and a notice U/s. 143(2) was issued on 15/09/2014 but the assessment got abated as search

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISAKHAPATNAM vs. ANUMOLU TIRUPATI RAYUDU(HUF),, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

14A of the Act to the extent of Rs.19,27,456/- having not satisfied with the assessee’s explanation that though the assessee made investments in certain companies which was made in the earlier years and no dividend was received during the year and no expenditure was incurred either. 7. The Ld. AO also made addition

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

14A of the Act to the extent of Rs.19,27,456/- having not satisfied with the assessee’s explanation that though the assessee made investments in certain companies which was made in the earlier years and no dividend was received during the year and no expenditure was incurred either. 7. The Ld. AO also made addition

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

14A of the Act to the extent of Rs.19,27,456/- having not satisfied with the assessee’s explanation that though the assessee made investments in certain companies which was made in the earlier years and no dividend was received during the year and no expenditure was incurred either. 7. The Ld. AO also made addition

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 104, 105 & 106/Viz/2020 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2015-16) Dy. Commissioner Of Income Tax, Vs. M/S. Atr Ware Housing (P) Central Circle-2, Ltd., Visakhapatnam. Visakhapatnam. Pan: Aadca 2121 Q

Housing (P) Ltd., Vs. Dy. Commissioner of Income Visakhapatnam. Tax, PAN: AADCA 2121 Q Central Circle-2, Visakhapatnam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant by : Sri G.V.N. Hari, Advocate ""याथ" क" ओर से / Respondent by : Sri MN Murthy Naik, CIT-DR सुनवाई क" तार"ख / Date of Hearing : 17/10/2022 घोषणा क" तार"ख/Date of : 21/12/2022 Pronouncement

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 104, 105 & 106/Viz/2020 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2015-16) Dy. Commissioner Of Income Tax, Vs. M/S. Atr Ware Housing (P) Central Circle-2, Ltd., Visakhapatnam. Visakhapatnam. Pan: Aadca 2121 Q

Housing (P) Ltd., Vs. Dy. Commissioner of Income Visakhapatnam. Tax, PAN: AADCA 2121 Q Central Circle-2, Visakhapatnam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant by : Sri G.V.N. Hari, Advocate ""याथ" क" ओर से / Respondent by : Sri MN Murthy Naik, CIT-DR सुनवाई क" तार"ख / Date of Hearing : 17/10/2022 घोषणा क" तार"ख/Date of : 21/12/2022 Pronouncement

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 104, 105 & 106/Viz/2020 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2015-16) Dy. Commissioner Of Income Tax, Vs. M/S. Atr Ware Housing (P) Central Circle-2, Ltd., Visakhapatnam. Visakhapatnam. Pan: Aadca 2121 Q

Housing (P) Ltd., Vs. Dy. Commissioner of Income Visakhapatnam. Tax, PAN: AADCA 2121 Q Central Circle-2, Visakhapatnam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant by : Sri G.V.N. Hari, Advocate ""याथ" क" ओर से / Respondent by : Sri MN Murthy Naik, CIT-DR सुनवाई क" तार"ख / Date of Hearing : 17/10/2022 घोषणा क" तार"ख/Date of : 21/12/2022 Pronouncement

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU vs. THE ANDHRA SUGARS LIMITED, TANUKU

In the result, appeal of the Revenue is dismissed

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No. 380/Viz/2019 (धनिाारणिर्ा/ Assessment Year: 2012-13) Assistant Commissioner Of Vs. M/S. Andhra Sugars Ltd., Income Tax, Circle-1, Tanuku. Eluru. Pan: Aaact6357Q (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) सी.ओ सं. / C.O. No. 140/Viz/2019 [आयक अपील सं. से उत्पन्न / Arising Out Of I.T.A. No. 380/Viz/2019(A.Y. 2012-13)] M/S. Andhra Sugars Ltd., Vs. Assistant Commissioner Of Tanuku. Income Tax, Circle-1, Pan: Aaact6357Q Eluru. अपीलार्थीकीओरसे/ Assessee By : Shri C. Subrahmanyam, Ca प्रत्यार्थीकीओरसे/ Revenue By : Dr.Satyasai Rath, Cit-Dr

14A of the Act on pro-rata basis due to the fact that the assessee has earned exempt income during the impugned assessment year. It was the contention of the Ld. AO that the assessee has not utilized own funds for the purpose of investment in shares and has failed to provide any evidence regarding the utilization of own funds