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

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

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

In the result, all the appeals filed by the revenue, viz

Bench: Shri Ravish Sood & Shri Balakrishnan S.

house property. It is seen that the case laws discussed above are applicable to the facts of the case of the appellant and hence respectfully following above decisions of various courts the addition of AO is deleted. AO to treat the receipt as business receipt and not rental receipts. Without prejudice Ground 3 - Interest disallowed Rs 17.37 crores on capital

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

In the result, all the appeals filed by the revenue, viz

Bench: Shri Ravish Sood & Shri Balakrishnan S.

house property. It is seen that the case laws discussed above are applicable to the facts of the case of the appellant and hence respectfully following above decisions of various courts the addition of AO is deleted. AO to treat the receipt as business receipt and not rental receipts. Without prejudice Ground 3 - Interest disallowed Rs 17.37 crores on capital

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

3 - Interest disallowed Rs 17.37\ncrores on capital borrowed to construct properties.\nAO added back on ground that appellant did not submit details\nof buildings constructed, plan approval of local authorities, income\nexpense working of these buildings. Appellant submitted certificate of\nCA regarding utilization of loan for construction of the properties as\nadditional evidence. The certificate stated that appellant

ARABOLU VENKATA NAGA DEEPATHI REPRESENTED BY POWER OF ATTORNEY HOLDER, N. SATYARAMANUJAMM ,VISAKHAPATNAM vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), VISAKHAPATNAM

In the result, the appeal fails and the same is hereby dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.178/Viz/2018 (ननधधारण वर्ा/ Assessment Year : 2010-11) Smt.Arabolu Venkata Naga Deepthi Vs. Income Tax Officer Rep. By Power Of Attorney Holder (International Taxation) Smt. N.Satyaramanujam Visakhapatnam Flat No.403, Dhanna Apartments Seethammadhara Visakhapatnam [Pan : Atcpa6413A] (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

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

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

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), , GUNTUR vs. BBM ESTATES PRIVATE LIMITED, GUNTUR

In the result, Revenue appeal is allowed and the C

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnan.आ.अपी.सं /Ita No.185/Viz/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Acit Vs. Bbm Estates (P) Ltd Circle 1(1) Guntur Guntur Pan: Aaace2607G (Appellant) (Respondent) C.O No.12/Viz/2024 (Arising Out Of Ita No.1895/Viz/2024) Bbm Estates (P) Ltd Vs. Acit Guntur Circle 1(1) Pan: Aaace2607G Guntur (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri G.V.N. Hari, Ca राज" व "ारा/Revenue By:: Shri Satyasai Rath, Dr सुनवाई की तारीख/Date Of Hearing: 07/01/2025 घोषणा की तारीख/Pronouncement: 01/04/2025 आदेश/Order

B) Page 10 of 17 ITA No 185 of 2024 and CO 12 of 2024 BBM Estates P Ltd respectively. The main object of the appellant company is to acquire and hold the properties known as "Chennai House" and "Firhavin Estate" both in Chennai and to let out those properties as well as make advances upon the security of lands

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

Bench: Us:

B). Addl. CIT Vs. Glad Investments (P) Ltd. (2006) 8 SOT 612 (Delhi) In the case before the Tribunal, the assessee owned 11,72,900 shares costing Rs. 20.06 crores and such shares were offered as guarantee for the loan taken by a company. Thereafter, the company defaulted and the lender sold the shares and appropriated the sale proceeds against

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)

b) or clause (c) of this sub- section, the amount of actual rent received or receivable by the owner shall not include, subject to such rules as may be made in this behalf, the amount of rent which the owner cannot realise.” 9. On the plain readding of Section 23(1) of the Act, it can be observed that annual

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

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

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

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

INDIRA VOONA,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-3(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. 244/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2017-18) Indira Voona V. Income Tax Officer – Ward 3(1) Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A. No. 268/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2015-16) Income Tax Officer – Tds Ward -1 Indira Voona V. Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

B: 1,92,000 C: Savings of F.Y. 2015-16 Rent 2,40,000 Miscellaneous Income 4,80,000 7,20,000 24,12,000 Page No. 3 I.T.A. No. 244 & 268/VIZ/2023 Indira Voona 5. The Ld.AO considering the explanation by the assessee being not satisfactory treated the cash deposits during the demonetization period aggregating

INDIRA VOONA,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, TDS WARD 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. 244/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2017-18) Indira Voona V. Income Tax Officer – Ward 3(1) Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A. No. 268/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2015-16) Income Tax Officer – Tds Ward -1 Indira Voona V. Visakhapatnam Plot No. 24, Sector 12 Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh [Pan: Aewpv1518E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

B: 1,92,000 C: Savings of F.Y. 2015-16 Rent 2,40,000 Miscellaneous Income 4,80,000 7,20,000 24,12,000 Page No. 3 I.T.A. No. 244 & 268/VIZ/2023 Indira Voona 5. The Ld.AO considering the explanation by the assessee being not satisfactory treated the cash deposits during the demonetization period aggregating