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

26 of the P/L a/c.\nAO relied on decision of the Hon'ble Apex court in the case of\nShambhu Investment (P.P Ltd. reported in 263 ITR 143) wherein the\nSupreme Court declined to interfere with the conclusion arrived at by\nCalcutta High Court on identical facts that the prime object of the\nassessee under the agreement

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

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

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 142(1) of the Act dated 12.06.2019 was issued calling for certain information from the assessee. As there was no compliance from the assessee, Ld. AO issued a show-cause notice dated 24.09.2019 requesting the assessee to show cause why the rent received cannot be charged to tax as “Income from House Property”. The assessee responded belatedly

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 142(1) of the Act dated 12.06.2019 was issued calling for certain information from the assessee. As there was no compliance from the assessee, Ld. AO issued a show-cause notice dated 24.09.2019 requesting the assessee to show cause why the rent received cannot be charged to tax as “Income from House Property”. The assessee responded belatedly

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

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 Act r.w.s. 2(47)(v) of the I.T. Act, 1961. Therefore, the Assessing Officer

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

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 Act r.w.s. 2(47)(v) of the I.T. Act, 1961. Therefore, the Assessing Officer

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

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 Act r.w.s. 2(47)(v) of the I.T. Act, 1961. Therefore, the Assessing Officer

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

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 Act r.w.s. 2(47)(v) of the I.T. Act, 1961. Therefore, the Assessing Officer

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

Bench: Us:

26 ITA No.482/Viz/2024 & CO No.03/Viz/2025 Surendra Nath Gubbala of the subject property by the banks under SARFASI Act, 2002, had given a notice in the local newspapers about the dispute of the ownership a/w photocopies of the legal notices/press notifications, and had issued warnings to the general public from buying the subject property in auction of the banks

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

Bench: Shri Ravish Sood, Hon’Ble

section 143(1) of the Income-Tax Act, 1961 (for short, “the Act”), dated 27.01.2020 for the Assessment Year 2017-18. The assessee has assailed the impugned order on the following grounds of appeal: “1. The order of Ld. AO (CPC) as well as Ld CIT(A) are contrary to the facts and also the provisions / law applicable

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)

III(1), Visakhapatnam, the appellant Shri Kanumuri Narasimha Raju purchased land admeasuring 4502.2 Sq. yards (0.925 acres) situated at Vellanki Village, Anandapuram, Visakhapatnam District from Shri Nallu Madhusudhan Reddy & Smt Nallu Sirisha Reedy both non-resident Indians for a consideration of Rs.4,72,62,6000/-. The above information was gathered based on the copies of sale agreements & sale deed gathered

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

properties purchased, investments, loans and advances during the FY 2013-14 and also asked to furnish the sources towards cash deposits in bank accounts. In response the Assessee’s Representative furnished the copies of the housing loan maintained at Andhra Bank, Tirupati. The Ld. AR submitted that the loans were claimed as expenditure as the loan is utilized for personal

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

properties purchased, investments, loans and advances during the FY 2013-14 and also asked to furnish the sources towards cash deposits in bank accounts. In response the Assessee’s Representative furnished the copies of the housing loan maintained at Andhra Bank, Tirupati. The Ld. AR submitted that the loans were claimed as expenditure as the loan is utilized for personal

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

properties purchased, investments, loans and advances during the FY 2013-14 and also asked to furnish the sources towards cash deposits in bank accounts. In response the Assessee’s Representative furnished the copies of the housing loan maintained at Andhra Bank, Tirupati. The Ld. AR submitted that the loans were claimed as expenditure as the loan is utilized for personal

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

properties purchased, investments, loans and advances during the FY 2013-14 and also asked to furnish the sources towards cash deposits in bank accounts. In response the Assessee’s Representative furnished the copies of the housing loan maintained at Andhra Bank, Tirupati. The Ld. AR submitted that the loans were claimed as expenditure as the loan is utilized for personal