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.

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the Gattula Lakshmi Madhavi vs. ACIT validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have

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.

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the Gattula Lakshmi Madhavi vs. ACIT validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have

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.

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the Gattula Lakshmi Madhavi vs. ACIT validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have

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 society is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.456/Viz/2025 (िनधा"रण वष"/Assessment Year:2019-20) No.368 Kolakaluru Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-1, Credit Society Limited, Tenali. Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W Section 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have no relevance

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 :

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the validity of the jurisdiction of an A.O would get triggered only in a case 11 Satyanarayana Koduru vs. ITO where the dispute of the assessee is with respect to the territorial jurisdiction and have

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:

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have no relevance

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

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have no relevance

GO IRON MARKETING,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD 3(3), VISHAKAPATNAM

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

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.483/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Go Iron Marketing, Vs. Income Tax Officer, Visakhapatnam. Ward-3(3), Pan: Aanfg6474D Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca (Hybrid Hearing) राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of 03/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 26/07/2025 Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 01/02/2024 For The Assessment Year 2018-19. The 2 Go Iron Marketing Vs. Ito

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have no relevance

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:

2) of Section 120, therefore, the provisions of sub-section (3) of Section 124 which puts a restriction on an assessee to object to the validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and have no relevance

ACIT, EXEMPTIONS,, VIJAYAWADA vs. SRI PRAKASHA EDUCATIONAL SOCIETY,, TUNII

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

30,96,505/- 2010-11 - 2011-12 - ` 70,44,262/- M/s. Sri Prakash Educational Society, Tuni 2.3 The assessee explained to A.O. stating that it had received the voluntary contributions from the parents of the children towards the development fees for creating infrastructure in the school such as construction of buildings, etc. and the same is in the nature

ACIT,, VIJAYAWADA vs. SRI PRAKASH EDUCATIONAL SOCIETY, TUNI

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

30,96,505/- 2010-11 - 2011-12 - ` 70,44,262/- M/s. Sri Prakash Educational Society, Tuni 2.3 The assessee explained to A.O. stating that it had received the voluntary contributions from the parents of the children towards the development fees for creating infrastructure in the school such as construction of buildings, etc. and the same is in the nature

ACIT, (EXEMPTIONS), EXEMPTIONS CIRCLE,, VIJAYAWADA vs. SRI PRAKASH EDUCATIONAL SOCIETY,, TUNI,

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

30,96,505/- 2010-11 - 2011-12 - ` 70,44,262/- M/s. Sri Prakash Educational Society, Tuni 2.3 The assessee explained to A.O. stating that it had received the voluntary contributions from the parents of the children towards the development fees for creating infrastructure in the school such as construction of buildings, etc. and the same is in the nature

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)

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C. Corollary being that after seizing of operational period of Section 153A to 153D, the cases being dealt thereunder were circumscribed in the scope of newly substituted Section 148. 29. The Department

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

In the result, appeal of the assessee is dismissed

Bench: Shri Ravish Sood, Hon'Ble**

reassessment proceedings, results in denial of substantive justice for mere procedural non-compliance.* - *3. Judicial precedents supporting the Appellant:* - *A. CIT v. G.M. Knitting Industries (P) Ltd. [(2015) 376 ITR 456 (SC)]: The Supreme Court held that a return filed under Section 139(4) is valid, and deduction cannot be denied merely for not filing under Section

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

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 issued under section 148 dated 29.07.2022 is invalid as the same is issued by the Jurisdictional AO as against Faceless AO as per the scheme framed under section 151A and notified

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)

reassessment order dated 16.01.2024 also is bad in law.” (emphasis supplied by us) 19. We find that the Hon’ble High Court in its aforesaid order had not only observed that in the case of the assessee before them ie., for AY 2018-19 the specified authority for granting approval under section 151 of the Act was the Principal Chief

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:

Section 147 2 N. Veerabrahmam r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 (for short “the Act”) dated 31.01.2024 for A.Y. 2018-19. The assessee has assailed the impugned order on the following grounds of appeal before us: “1. The order of the learned Commissioner of Income Tax (Appeals) is contrary to the facts and also

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

In the result, the appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon'Ble**

2) of the Act is barred by limitation and therefore is liable to be quashed as invalid and the consequent assessment proceedings are liable to be quashed as void ab initio."* - **9.** We admit the legal grounds raised by the assessee as additional grounds since it assails the validity of the assessment order and goes to the root

HOTEL SELECTION GRAND,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

Bench: Shri Ravish Sood, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपीलसं./I.T.A.No.741/Viz/2025 (निर्धारण वर्ष / Assessment Year:2016-17) Hotel Selection Grand Gollagundam Centre K.N. Road Tadepalligudem-534101 Andhra Pradesh [Pan: Aakfh0778C] Vs. Income Tax Officer, Ward -1 Aayakar Bhavan, 2-1-56/1 Opp. Punjab National Bank K.N.Road, Tadepalligudem – 534101 Andhra Pradesh करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement Per Ravish Sood, Jm: : Shri I. Kama Sastry, Ca : Sri K.Prasad, Sr.Dr : 12.02.2026 : 18.02.2026 आदेश /Order The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 24.10.2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short "A.O”) Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (For Short, "The Act"), Dated 06.01.2025 For The Assessment Year 2016-17. The Assessee Firm Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us: "1. The Notice Under Section 148 Issued On 18.04.20232 For The

2. The notice issued under section 148 dated 18.04.2023 is invalid as it has given only 30 days-time from the date of service of the notice for filing response thereto as against the period of three months from the end of the month in which the notice is issued as mandated by the provisions of section 148 with effect