DEPUTY COMMISSIONER OF INCOME TAX (IT), VISAKHAPATNAM vs. SHRI APPARAO MUKKAMALA, USA

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

reassessing the unabated assessment on the basis of material received from the other sources and can proceed under section 148. The decision does not support the contentions raised that Section 148 is rendered redundant if Section 153C is to be resorted to in the facts of the present case. 36. The Single Bench of this Court in the case

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)

131(1A) of the assessee or any other person/ appraisal report of the Investigation Wing of the Department/ materials on hand with the Department at the time of initiation of search or material evidences gathered were placed for its verification and the same were duly verified and/or examined by him as mandated under section 153D. In the absence of compliance

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)

131(1A) of the assessee or any other person/ appraisal report of the Investigation Wing of the Department/ materials on hand with the Department at the time of initiation of search or material evidences gathered were placed for its verification and the same were duly verified and/or examined by him as mandated under section 153D. In the absence of compliance

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)

131(1A) of the assessee or any other person/ appraisal report of the Investigation Wing of the Department/ materials on hand with the Department at the time of initiation of search or material evidences gathered were placed for its verification and the same were duly verified and/or examined by him as mandated under section 153D. In the absence of compliance

INCOME TAX OFFICER, WARD-2(3), VIJAYAWADA vs. SREELAKSHMI MUSUNURU, PENAMALURU

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.278/Viz/2024 (िनधा"रण वष"/Assessment Year: 2013-14) Income Tax Officer, Vs. Sreelakshmi Musunuru, Ward-2(3), Penamaluru. Vijayawada. Pan: Aojpm4884K (Appellant) (Respondent)

131 of APB), vide her letter dated 23.11.2015 filed with the A.O in the course of the original assessment proceedings, disclosed all the primary facts regarding the purchase of agricultural land at Gangur (Page 133- 135 of APB), she was not required to give any further assistance to the AO by disclosure of other facts. Rather

PANDALAPAKA PRIMARY AGRICULTURAL CO-OP SOCIETY LTD,EAST GODAVARI vs. INCOME-TAX OFFICER, WARD-1, KAKINADA

131/- with the D.C.C.BANK, RAYAVARAM. Since the deduction\nunder section 80P of the Act is available only for the profits and gains of the\nbusiness of assessee (providing credit facilities to the members), the said\ndeduction is not available to the interest income which is in the nature of 'other\nincome' or 'income from other sources'. Accordingly show-cause notice

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISKAHAPATNAM vs. SRI VIJAYA VISAKHA MILK PRODUCERS COMPANY LIMITED,, VISAKHAPATNAM

In the result, appeals filed by the revenue and the cross objections filed by the assessee are dismissed for the A

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.239/Viz/2020 & 237/Viz/2020 (ननधधारण वर्ा/ Assessment Year : 2012-13 &2013-14) Assistant Commissioner Of Vs. M/S Sri Vijaya Visakha Milk Income Tax Producers Company Limited Central Circle-2 Visakha Diary, Bhpv Post Visakhapatnam Nh-5, Nathayyapalem Visakhapatnam [Pan :Aajcs7398P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

131(1A) of the Act was recorded from Shri Lalam Arjuna Rao, Managing Partner of Shri Siridi Sai Agencies on 31.10.2016, who stated that Shri Siridi Sai Agencies is an intermediary agency, supplying milk in bulk milk tankers to M/s Visakha Milk Products Private Ltd. He further stated that he was not aware of the fixation of the prices

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

131 issued during the course of assessment proceedings. 3. The Ld. CIT(A) erred in deleting the additions of Rs.1,00,00,000/- ignoring the fact that during the course of search operation, a statement on oath of Sri. Rajesh G. Mehta was recorded wherein he admitted that he was only providing bogus sales and purchase bill to Vedumutha Electricals

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

131 issued during the course of assessment proceedings. 3. The Ld. CIT(A) erred in deleting the additions of Rs.1,00,00,000/- ignoring the fact that during the course of search operation, a statement on oath of Sri. Rajesh G. Mehta was recorded wherein he admitted that he was only providing bogus sales and purchase bill to Vedumutha Electricals

THE INCOME TAX OFFICER, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

131 issued during the course of assessment proceedings. 3. The Ld. CIT(A) erred in deleting the additions of Rs.1,00,00,000/- ignoring the fact that during the course of search operation, a statement on oath of Sri. Rajesh G. Mehta was recorded wherein he admitted that he was only providing bogus sales and purchase bill to Vedumutha Electricals

ACIT, CIRCLE-1(1),, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

131 issued during the course of assessment proceedings. 3. The Ld. CIT(A) erred in deleting the additions of Rs.1,00,00,000/- ignoring the fact that during the course of search operation, a statement on oath of Sri. Rajesh G. Mehta was recorded wherein he admitted that he was only providing bogus sales and purchase bill to Vedumutha Electricals

ACIT, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

131 issued during the course of assessment proceedings. 3. The Ld. CIT(A) erred in deleting the additions of Rs.1,00,00,000/- ignoring the fact that during the course of search operation, a statement on oath of Sri. Rajesh G. Mehta was recorded wherein he admitted that he was only providing bogus sales and purchase bill to Vedumutha Electricals

ARRDY ENGINEERING INNOVATINS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

reassessment proceedings U/s. 147 is not permissible merely on the basis of change of opinion because the AO for subsequent AY 2006-07 had taken a view that weighted deduction U/s. 35(2AB) cannot be allowed. 3. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field

ARRDY ENGINNERING INNOVATIONS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

reassessment proceedings U/s. 147 is not permissible merely on the basis of change of opinion because the AO for subsequent AY 2006-07 had taken a view that weighted deduction U/s. 35(2AB) cannot be allowed. 3. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field

NALLURU CONSTRUCTIONS,VIJAYAWADA vs. INCOME TAX OFFICER, CIRCLE-1(1), VIJAYAWADA

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Omkareshwar Chidaraआ.अपी.सं /Ita No.646/Viz./2025 Assessment Year 2015-2016 Nalluru Constructions, The Income Tax Officer, Vijayawada–520 010. Circle-1(1), Andhra Pradesh. Vijayawada. Vs. State Of Andhra Pradesh Pan Aaifn5778N (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri C Subrahmanyam, Ca राज" व "ारा /Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 27.01.2026 घोषणा की तारीख/Pronouncement: 30.01.2026 आदेश/Order

3. The assessee has also raised additional grounds of appeal under Rule 29 of ITAT Rules, 1963 which read as under: 1. “The notice issued u/s 148 dt. 03-04-2022 is barred by limitation as per section 149(1)(b) read with the proviso thereto, having been issued beyond the prescribed period of six years. Consequently, the reassessment order