SATYA VENKATA KRISHNA RAVI PRASAD KODURI,RAJAHMUNDRY vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

5 Taxman 92 (MP.) and Addl. CWT v.\nNathoolalBalaram [1980] 125 ITR 596/3 Taxman 170 (MP.) had\nconcluded that where the CIT finds that the Assessing Officer had not\ninitiated penalty proceedings under Section 271(1)(c) of the Act in the\nassessment order, he cannot direct the Assessing Officer to initiate penalty\nproceedings under Section 271

VEERA VENKATA RAMAKRISHNA MOHANA RAO KODURI,RAJAHMUNDRY vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita Nos. 290 & 291/Viz/2025 निर्धारण वर्ा/ Assessment Years:2018-19 & 2019-20) Veera Venkata Ramakrishna V. Acit – Circle – 1 Mohana Rao Koduri Ayakkar Bhawan Flat No. 201, Sri Towers Nh-16 Veerabadhrapuram Venkateswara Nagar Rajahmundry – 533105 Syamalanagar Andhra Pradesh East Godavari District - 533103 Andhra Pradesh [Pan:Afrpk0888C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita Nos. 293 & 294/Viz/2025 निर्धारणवर्ा/ Assessment Years:2018-19 & 2019-20) Satya Venkata Krishna Ravi V. Acit – Circle – 1 Prasad Koduri Ayakkar Bhawan 81-10-3/6, Venkateswaranagar Veerabadhrapuram Near Ima Halla, Danavaipeta Rajahmundry – 533105 East Godavari District Andhra Pradesh Andhra Pradesh [Pan:Afrpk0889D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt Hemalatha K, Ca राजस्व का प्रतततितित्व/ Department Represented By : Shri Badicala Yadagiri, Cit(Dr)

5 Taxman 92 (MP.) and Addl. CWT v. NathoolalBalaram [1980] 125 ITR 596/3 Taxman 170 (MP.) had concluded that where the CIT finds that the Assessing Officer had not initiated penalty proceedings under Section 271(1)(c) of the Act in the assessment order, he cannot direct the Assessing Officer to initiate penalty proceedings under Section 271

VEERA VENKATA RAMAKRISHNA MOHAN RAO KODURI,EAST GODHAVARI vs. ACIT, CIRLCE - 1, RAJAHMUNDRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita Nos. 290 & 291/Viz/2025 निर्धारण वर्ा/ Assessment Years:2018-19 & 2019-20) Veera Venkata Ramakrishna V. Acit – Circle – 1 Mohana Rao Koduri Ayakkar Bhawan Flat No. 201, Sri Towers Nh-16 Veerabadhrapuram Venkateswara Nagar Rajahmundry – 533105 Syamalanagar Andhra Pradesh East Godavari District - 533103 Andhra Pradesh [Pan:Afrpk0888C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita Nos. 293 & 294/Viz/2025 निर्धारणवर्ा/ Assessment Years:2018-19 & 2019-20) Satya Venkata Krishna Ravi V. Acit – Circle – 1 Prasad Koduri Ayakkar Bhawan 81-10-3/6, Venkateswaranagar Veerabadhrapuram Near Ima Halla, Danavaipeta Rajahmundry – 533105 East Godavari District Andhra Pradesh Andhra Pradesh [Pan:Afrpk0889D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt Hemalatha K, Ca राजस्व का प्रतततितित्व/ Department Represented By : Shri Badicala Yadagiri, Cit(Dr)

5 Taxman 92 (MP.) and Addl. CWT v. NathoolalBalaram [1980] 125 ITR 596/3 Taxman 170 (MP.) had concluded that where the CIT finds that the Assessing Officer had not initiated penalty proceedings under Section 271(1)(c) of the Act in the assessment order, he cannot direct the Assessing Officer to initiate penalty proceedings under Section 271

SATYA VENKATA KRISHNA RAVI PRASAD KODURI,EAST GODHAVARI vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

5 Taxman 92 (MP.) and Addl. CWT v.\nNathoolalBalaram [1980] 125 ITR 596/3 Taxman 170 (MP.) had\nconcluded that where the CIT finds that the Assessing Officer had not\ninitiated penalty proceedings under Section 271(1)(c) of the Act in the\nassessment order, he cannot direct the Assessing Officer to initiate penalty\nproceedings under Section 271

MALLA APPALARAJU,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-5(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

45,268/-, directed the Ld. AO to re-compute the income @ 5% of the purchase price of the stock which was put to sale, net of all the 3 deduction. With regard to addition made by the Ld. AO towards unexplained investment U/s. 69, the Ld. CIT(A) has upheld the decision of the Ld.AO. Thereafter, the Ld. AO issued

KOTI NARASIMHA REDDY GUTTIKONDA,GUNTUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX , VIJAYAWADA

In the result, appeal of the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.332/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2016-17) Koti Narasimha Reddy Guttikonda Vs. Pr. Cit 1-99, Rudravaram – 522410 Siddhardha Public School Road Guntur District, Andhra Pradesh Mogalrajapurm Vijayawada – 520010 [Pan: Amcpg7882N] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri K.Siva Ram Kumar, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

5 I.T.A.No.332/VIZ/2025 Koti Narasimha Reddy Guttikonda Commissioner and it is not possible when the Commissioner is dealing with the assessment proceedings and the assessment order to expand the scope of these proceedings and to view the penalty proceedings also as part of the proceedings which are being sought to be revised by the Commissioner. There is no identity between

GINJALA ATCHIRAJU, L/R. OF GINJALA SIMHADRI RAJU, ,KAKINADA vs. INCOME-TAX OFFICER, WARD -1, , KAKINADA

In the result, appeal of the assessee is partly allowed

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

45,155/-. The assessee during the course of the survey operations submitted that he has erroneously considered the sale consideration and the cost of acquisition and hence correct long term capital gains could not be admitted in his return of income. He also submitted that the entire investment in the land and buildings was made by him and his daughter

RAKESH KUMAR JAIN,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-2(1), VIJAYAWADA

In the result, appeal of the assessee is partly allowed

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.361/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Madhu Devi V. Income Tax Officer – Ward – 2(1) C.R. Building, 1St Floor Annex #27-23-66, Chetla Bazar M.G. Road, Vijayawada – 520002 Governorpet, Vijayawada – 520002 Andhra Pradesh Andhra Pradesh [Pan: Aelpj0707L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपीलसं./I.T.A.No.362/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Rakesh Kumar Jain V. Income Tax Officer – Ward – 2(1) C.R. Building, 1St Floor Annex D.No. 27-12-35, Chetla Bazar M.G. Road, Vijayawada – 520002 Governorpet, Vijayawada – 520002 Andhra Pradesh Andhra Pradesh [Pan: Astps2713B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

45,05,000/-) in cash towards sale consideration of immovable property vide sale deed No. 3155/2016 dated 20.10.2016. Ld. AO observed that assessee has contravened the provisions of section 269SS of the Act and issued show-cause notice dated 23.03.2021. In response, assessee filed her reply. After perusing the reply of the assessee, Ld. AO being not convinced with

VISAKHAPATNAM PORT AUTHORITY, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, , VISAKHAPTNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

45,090/-. The Ld. CIT-1, Visakhapatnam duly exercising his powers U/s. 263 of the Act noticed from the tax audit report annexed to the return of income that the assessee has claimed a sum of Rs. 10,15,39,759/- U/s. 43B of the Act on payment basis which included a sum of Rs. 5,09,64,466/- pertaining