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).0f the Income Tax Act, 1961- Income from house property-chargeable us (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).0f the Income Tax Act, 1961- Income from house property-chargeable us (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

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

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

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

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

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

Bench: Us:

36 ITA No.482/Viz/2024 & CO No.03/Viz/2025 Surendra Nath Gubbala 40. As observed hereinabove, the purchasers of the property, viz. M/s APSN Properties LLP & Ors., as per the terms of the MoU, dated 13.06.2019, had agreed to directly make payment to the banks, viz. SBI and Axis Bank Ltd., Vishakapatnam, for the release of the subject property that was mortgaged with them

YALAMANCHILI NEELIMA,,GUNTUR vs. THE INCOME TAX OFFICER, WARD-2(2),, GUNTUR

In the result, appeal of the assessee is partly allowed for statistical purposes

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

section 53A of the Transfer of Property Act considered the property as 3 transferred during the assessment year 2016-17. The Ld. AO noticing that the assessee has not filed return of income for the AY 2016-17 believed that the income chargeable to tax escaped assessment and notice u/s. 148 of the Act was issued and served

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

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 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

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