VENKATA PRASAD PULIPATI,AMARAVATHI vs. INCOME-TAX OFFICER, WARD-2(1), GUNTUR

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.612/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Venkata Prasad Pulipati, Vs. Income Tax Officer, Amaravathi. Ward-2(1), Pan: Asapp8796L Guntur. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri I. Kama Sastry, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per show cause notice issued under clause (b) of section 148A

ASHOK RUDRARAJU,VISAKHAPATNAM vs. INCOME-TAX OFFICER,WARD-2(5), VISAKHAPATNAM

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L

4. Without prejudice to the above grounds, the order passed under section 147 r.w.s 1448 dated 09.05. 2023 is barred by limitation 5. Without prejudice to the above grounds, the addition of Rs. 30,12,755 /- as unexplained money under section 69A is unjustified and invalid and not as per the provisions of section 69A (Additional ground) 9. The notice

INCOME TAX OFFICER, WARD-2(5), VISAKHAPATNAM vs. DUVVURU REKHA REDDY, KURMANNAPALEM

In the result, the cross objection filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.450/Viz/2024 (निर्धारण वर्ा/ Assessment Year:2017-18) Vs. Income Tax Officer –Ward– 2(5) Duvvuru Rekha Reddy 2Nd Floor, Infinity Towers Flat No. 402, Vizag Profile Towers Sankaramatam Road Kurmannapalem Visakhapatnam - 530016 Visakhapatnam -530046 Andhra Pradesh [Pan:Afdpr3780C] सी.ओ सं. / C.O. No. 17/Viz/2024 [आयकरअपीलसं.से उत्पन्न/I.T.A.No.450/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18)] Vs. Income Tax Officer –Ward– 2(5) Duvvuru Rekha Reddy 2Nd Floor, Infinity Towers Flat No. 402, Vizag Profile Towers Sankaramatam Road Kurmannapalem Visakhapatnam - 530016 Visakhapatnam - 530046 Andhra Pradesh [Pan:Afdpr3780C]

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per showcause notice issued under clause (b)of section 148A

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. VIZAG RE-BARS PRIVATE LIMITED, VISAKHAPATNAM

In the result, the cross objection filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per showcause notice issued under clause (b)of section 148A

POTHINA SATYANARAYANA,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-2(5), VISAKHAPATNAM

In the result, 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.568/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Pothina Satyanarayana, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahdpp1312N Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 19/11/2025 Hearing: घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 10/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 12/02/2024 For The Assessment Year 2018-19. The 2 Pothina Satyanarayana Vs. Ito

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per show cause notice issued under clause (b) of section 148A

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

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.455/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) No. 368 Kolakaluru Vs. The Income Tax Officer, Primary Agricultural Co- Ward-1, Operative Credit Society Tenali. Limited, Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/10/2025 घोषणा की तारीख/Date Of 10/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee-Society Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 25/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The 2 No. 368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs. Ito

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: 16 No. 368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs. ITO Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee

UPPALAPADU PRIMARY AGRICULTURAL COOPERATIVE SOCIETY LIMITED,UPPALAPADU, GUNTUR vs. INCOME TAX OFFICER, WARD-2(1), GUNTUR

Bench: Shri Ravish Sood & Shri Balakrishnan Sआ.अपी.सं /Ita No.523/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Uppalapadu Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-2(1), Society Limited, Guntur. Uppalapadu, Guntur. Pan: Aaaau4669G (Appellant) (Respondent) िनधा"रती Shri R. Siva Rama Krishna, "ारा/Assessee By: Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 29/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Society Is Directed Against The Assessment Order Dated 25.01.2024 Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Read With Sections 144 & 144B Of The Income-Tax Act, 1961 (For Short, “The Act”) Dated 25.01.2024 For The Assessment Year 2018-19. The 2 Uppalapadu Primary Agricultural Cooperative Society Limited Vs. Ito

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per show cause notice issued under clause (b) of section 148A

MARISETTI DHANA TATAJI,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

132 or books\nof account, other documents or any assets requisitioned under section 132A, on\nor before the 31st day of March, 2021:\nProvided also that for the purposes of computing the period of limitation as per\nthis section, the time or extended time allowed to the assessee, as per showcause\nnotice issued under clause (b)of section 148A

NANDIGAM VEERABRAHMAM,RAJAHMUNDRY vs. INCOME TAX OFFICER, WARD-2(1), RAJAHMUNDRY

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Us:

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per showcause notice issued under clause (b) 17 N. Veerabrahmam

INCOME TAX OFFICER, TENALI vs. SURYAPRAKASARAO KANAPARTHY, BETHAPUDI, REPALLE

In the result, the Cross Objection filed by the assessee is allowed in terms of our aforesaid observations, while for the appeal filed by the revenue having been rendered as academic in nature, is ...

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.239/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Income Tax Officer, Vs. Suryaprakasarao Tenali. Kanaparthy, Bethapudi, Repalle, Bapatla. Pan: Dmqpk7509P (Appellant) (Respondent)

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per show cause notice issued under clause (b) of section 148A

INCOME TAX OFFICER, INFINITY TOWERS, SANKARMATHAM ROAD vs. AMMAJI CHENNUPATI, RAJEEVNAGAR, KURMANNAPALEM

In the result, the appeal of the revenue is dismissed, while the additional ground of cross-objection of the assessee is allowed in terms of our aforesaid observations

Bench: Us:

132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per showcause notice issued under clause (b) of section 148A

MARISETTI DHANA TATAJI,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

132 or books\nof account, other documents or any assets requisitioned under section 132A, on\nor before the 31st day of March, 2021:\nProvided also that for the purposes of computing the period of limitation as per\nthis section, the time or extended time allowed to the assessee, as per showcause\nnotice issued under clause (b)of section 148A

MARISETTI DHANA TATAJI,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

132 or books\nof account, other documents or any assets requisitioned under section 132A, on\nor before the 31st day of March, 2021:\nProvided also that for the purposes of computing the period of limitation as per\nthis section, the time or extended time allowed to the assessee, as per showcause\nnotice issued under clause (b)of section 148A

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)

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause

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)

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause

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)

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause

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)

132 is initiated or requisition under section 132A is made on or after the 1st day of April, 2017. Explanation 1.—For the purposes of this sub-section, the expression "relevant assessment year" shall mean an assessment year preceding the assessment year relevant to the previous year in which search is conducted or requisition is made which falls beyond

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened