INCOME TAX OFFICER, INCOME TAX DEPARTMENT, VISAKHAPATNAM vs. QUALITY STEEL SHOPPE PRIVATE LIMITED, VISAKHAPATNAM

In the result, the Cross Objection No

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.454/Viz/2024 ("नधा"रण वष"/Assessment Year: 2018-19) Income Tax Officer, Vs. Quality Steel Shoppe Ward-2(1), Private Limited, Visakhapatnam. Visakhapatnam. Pan: Aaacq1115D (Appellant) (Respondent) C.O. No. 18/Viz/2024 (In आ.अपी.सं /454/Viz/2024) ("नधा"रण वष"/Assessment Year: 2018-19)

10. In view of the above and for the reasons stated above, the present Appeals are ALLOWED IN PART. The impugned common judgments and orders passed by the High Court of Judicature at Allahabad in W.T. No. 524/2021 and other allied tax appeals/petitions, is/are hereby modified and substituted as under: (i) The impugned section 148 notices issued to the respective

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.

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 culminating the assessment, initiated penalty proceedings, viz., (i) under section 270A of the Act for under- reporting of income, in consequence of misreporting of income, in respect of business 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.

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 culminating the assessment, initiated penalty proceedings, viz., (i) under section 270A of the Act for under- reporting of income, in consequence of misreporting of income, in respect of business 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.

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 culminating the assessment, initiated penalty proceedings, viz., (i) under section 270A of the Act for under- reporting of income, in consequence of misreporting of income, in respect of business income

NUTHALAPATI RAVI SHANKAR,,PALACOLE vs. INCOME TAX OFFICER, WARD-1,, PALACOLE

In the result, appeals of the assessees are allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपीऱ सं./I.T.A.No.13 & 14/Viz/2019 (निर्धारण वषा/Assessment Years : 2008-09 & 2011-12) Thangirala Immanuel, Vs. Income Tax Officer Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपीऱ सं./I.T.A.No.16/Viz/2019 (निर्धारण वषा/Assessment Year : 2011-12) Avadhanula Srinivasa Rao Vs. Income Tax Officer Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपीऱ सं./I.T.A.No.25/Viz/2019 (निर्धारण वषा/Assessment Year: 2011-12) Vs. Income Tax Officer Nuthalapati Ravi Shankar Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) रधजस्व की ओर से /Revenue By : Shri G.V.N.Hari, Ar निर्धाररती की ओर से / Assessee By : Smt.Suman Malik, Ar सुिवधई की तधरीख / Date Of Hearing : 30.04.2019 घोषणध की तधरीख/Date Of Pronouncement : 29 .05.2019

reassessment proceedings the assessees have filed the reply stating that the exemption was claimed u/s 10(14), since, the amounts were wholly and exclusively spent on tour and travelling for mobilizing the business and are exempt under rule 2BB(1)(c) of the I.T.Rules. The AO considered the explanation of the assessee and not being satisfied with the explanation

THANGIRALA IMMANUEL,PALACOLE vs. THE INCOME TAX OFFICER, WARD-1, , PALACOLE

In the result, appeals of the assessees are allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपीऱ सं./I.T.A.No.13 & 14/Viz/2019 (निर्धारण वषा/Assessment Years : 2008-09 & 2011-12) Thangirala Immanuel, Vs. Income Tax Officer Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपीऱ सं./I.T.A.No.16/Viz/2019 (निर्धारण वषा/Assessment Year : 2011-12) Avadhanula Srinivasa Rao Vs. Income Tax Officer Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपीऱ सं./I.T.A.No.25/Viz/2019 (निर्धारण वषा/Assessment Year: 2011-12) Vs. Income Tax Officer Nuthalapati Ravi Shankar Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) रधजस्व की ओर से /Revenue By : Shri G.V.N.Hari, Ar निर्धाररती की ओर से / Assessee By : Smt.Suman Malik, Ar सुिवधई की तधरीख / Date Of Hearing : 30.04.2019 घोषणध की तधरीख/Date Of Pronouncement : 29 .05.2019

reassessment proceedings the assessees have filed the reply stating that the exemption was claimed u/s 10(14), since, the amounts were wholly and exclusively spent on tour and travelling for mobilizing the business and are exempt under rule 2BB(1)(c) of the I.T.Rules. The AO considered the explanation of the assessee and not being satisfied with the explanation

THANGIRALA IMMANUEL,PALAKOL vs. THE INCOME TAX OFFICER, WARD-1, , PALAKOL

In the result, appeals of the assessees are allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपीऱ सं./I.T.A.No.13 & 14/Viz/2019 (निर्धारण वषा/Assessment Years : 2008-09 & 2011-12) Thangirala Immanuel, Vs. Income Tax Officer Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपीऱ सं./I.T.A.No.16/Viz/2019 (निर्धारण वषा/Assessment Year : 2011-12) Avadhanula Srinivasa Rao Vs. Income Tax Officer Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपीऱ सं./I.T.A.No.25/Viz/2019 (निर्धारण वषा/Assessment Year: 2011-12) Vs. Income Tax Officer Nuthalapati Ravi Shankar Development Officer Ward-1 Lic Of India Palakol 1St Lane, Brodipeta Palakol (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) रधजस्व की ओर से /Revenue By : Shri G.V.N.Hari, Ar निर्धाररती की ओर से / Assessee By : Smt.Suman Malik, Ar सुिवधई की तधरीख / Date Of Hearing : 30.04.2019 घोषणध की तधरीख/Date Of Pronouncement : 29 .05.2019

reassessment proceedings the assessees have filed the reply stating that the exemption was claimed u/s 10(14), since, the amounts were wholly and exclusively spent on tour and travelling for mobilizing the business and are exempt under rule 2BB(1)(c) of the I.T.Rules. The AO considered the explanation of the assessee and not being satisfied with the explanation

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 :

10 Satyanarayana Koduru vs. ITO sub-section (3) of Section 124 of the Act, the same places a restriction upon an assessee to call in question the jurisdiction of the A.O where he had initially not raised such objection within a period of one month from the date on which he was served with a notice under sub-section

INCOME TAX OFFICER, WARD-1, GUDIWADA vs. CHAGANTIPADU PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LIMITED NOH957, CHAGANTIPADU VILLAGE,

10\nI.T.A. No. 641/VIZ/2025\nC.O. No. 42/VIZ/2025\nChagantipadu Primary Agri Coop Credit\nSociety Limited NOH957\n11. We have considered the submissions of both sides and perused the material\navailable on record. In the present case, there is no dispute regarding the fact that\nthe notice under section 148A(b) of the Act, the order under section 148A(d) of\nthe

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. DODDI ROOPA, VISAKHAPATNAM

In the result, the appeal filed by the revenue is dismissed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.413/Viz/2024 (िनधा"रण वष"/Assessment Year: 2019-20) Deputy Commissioner Of Vs. Smt. Doddi Roopa, Income Tax, Visakhapatnam. Circle-3(1), Visakhapatnam. Pan: Atfpr7237N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement:

reassessment or recomputation under Section 147 of the Act and inapplicable to the issuance of notice under Section 148 of the Act. The Scheme is clearly applicable for issuance of notice under Section 148 of the Act and accordingly, it is only the FAO which can issue the notice under Section

BATHINA KUMARA SWAMY REDDY,NELLORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee is allowed

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.287, 288 & 289/Viz/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy V. Dcit – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [Pan: Abxpb1094K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

29. He further submitted that if the bench decides the validity of the assessment order passed under section 143(3) r.w.s. 153A of the Act in accordance with the approval granted under section 153D of the Act holding the assessment order as void ab-initio, the other grounds become academic. He further submitted that on perusal of the letter dated

BATHINA KUMARA SWAMY REDDY,NELLORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee is allowed

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.287, 288 & 289/Viz/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy V. Dcit – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [Pan: Abxpb1094K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

29. He further submitted that if the bench decides the validity of the assessment order passed under section 143(3) r.w.s. 153A of the Act in accordance with the approval granted under section 153D of the Act holding the assessment order as void ab-initio, the other grounds become academic. He further submitted that on perusal of the letter dated

BTHINA KUMARA SWAMY REDDY,NELLORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee is allowed

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.287, 288 & 289/Viz/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy V. Dcit – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [Pan: Abxpb1094K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

29. He further submitted that if the bench decides the validity of the assessment order passed under section 143(3) r.w.s. 153A of the Act in accordance with the approval granted under section 153D of the Act holding the assessment order as void ab-initio, the other grounds become academic. He further submitted that on perusal of the letter dated

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:

10 Vikram Brahmendra Satyajit Mulpuri vs. ITO jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where he objects to the assumption of jurisdiction by the A.O, and not otherwise. 15. At this stage, we may herein refer to certain judicial pronouncements that had in the past held

KANUMURI SIVA RAMA RAJU,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

10. We have heard rival contentions and perused the material placed on record. It is seen from the order of the AO that the assessment was reopened on the basis of concealment of income estimated by the DDIT(Inv) in the appraisal report and made the additions on the basis of the joint receipt which was found and seized during

KUNUMURI KRISHNA KUMARI,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

10. We have heard rival contentions and perused the material placed on record. It is seen from the order of the AO that the assessment was reopened on the basis of concealment of income estimated by the DDIT(Inv) in the appraisal report and made the additions on the basis of the joint receipt which was found and seized during

KANUMURI PRASAD,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

10. We have heard rival contentions and perused the material placed on record. It is seen from the order of the AO that the assessment was reopened on the basis of concealment of income estimated by the DDIT(Inv) in the appraisal report and made the additions on the basis of the joint receipt which was found and seized during

KUNUMURI KRISHNA KUMARI,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

10. We have heard rival contentions and perused the material placed on record. It is seen from the order of the AO that the assessment was reopened on the basis of concealment of income estimated by the DDIT(Inv) in the appraisal report and made the additions on the basis of the joint receipt which was found and seized during