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

reassessment proceedings as per the substituted provisions of sections 147 to 151 of the IT Act as per the Finance Act, 2021, subject to compliance of all the procedural requirements and the defences, which may be available to the assessee under the substituted provisions of sections 147 to 151 of the IT Act and which may be available under

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

reassessment order dated 16.01.2024 also is bad in law.” (emphasis supplied by us) 18. 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 for AY 2018-19 the specified authority for granting approval under section 151 of the Act was the Principal Chief Commissioner

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:

reassessment proceedings as per the substituted provisions of sections 147 to 151 of the IT Act as per the Finance Act, 2021, subject to compliance of all the procedural requirements and the defences, which may be available to the assessee under the substituted provisions of sections 147 to 151 of the IT Act and which may be available under

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.

reassessment'. 23. It is noteworthy that the order of CBDT dated 06.09.2021 deals with "assessment orders". The said order is passed in exercise of power under Section 144B of the Act. The order of CBDT is clear that direction was issued about passing of "assessment orders" by the National Faceless Assessment Centre under Section 144B of the Act except

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.

reassessment'. 23. It is noteworthy that the order of CBDT dated 06.09.2021 deals with "assessment orders". The said order is passed in exercise of power under Section 144B of the Act. The order of CBDT is clear that direction was issued about passing of "assessment orders" by the National Faceless Assessment Centre under Section 144B of the Act except

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.

reassessment'. 23. It is noteworthy that the order of CBDT dated 06.09.2021 deals with "assessment orders". The said order is passed in exercise of power under Section 144B of the Act. The order of CBDT is clear that direction was issued about passing of "assessment orders" by the National Faceless Assessment Centre under Section 144B of the Act except

SIVA DURGA VARA PRASAD CHENNUPATI,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), VIJAYAWADA

In the result, the appeal by the assessee is allowed

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailita No.368/Viz/2025 (Assessment Year 2016-17) (Assessment Year 2016-17) Sivadurgavara Prasad Chennupati, H. No. 27-32-27, Raghu Paints, Mudda Subbaiah Street, Governorpet, Vijayawada ............... Appellant Pan: Aeepc5404L V/S Assistant Commissioner Of Income Tax, Circle – 2(1), ……………… Respondent C R Building, 1St Floor Annex, M.G. Road, Vijayawada Assessee By : Shri C.R. Hemanth Kumar, Ca Revenue By : Dr. Aparna Villuri, Sr. Ar

28(iv) of the Act being the pro-rata amount spent by M/s Asian Paints Ltd. on the assessee. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee. Being aggrieved, the assessee is in appeal before us. 10. During the hearing, the learned AR submitted that for the year under consideration, the limitation period available

SIVADURGAVARA PRASAD CHENNUPATI,VIJAYAWADA vs. ASSISTANT CIT, CIRCLE 2(1), VIJAYAWADA

In the result, the appeal by the assessee is allowed

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailita No.368/Viz/2025 (Assessment Year 2016-17) (Assessment Year 2016-17) Sivadurgavara Prasad Chennupati, H. No. 27-32-27, Raghu Paints, Mudda Subbaiah Street, Governorpet, Vijayawada ............... Appellant Pan: Aeepc5404L V/S Assistant Commissioner Of Income Tax, Circle – 2(1), ……………… Respondent C R Building, 1St Floor Annex, M.G. Road, Vijayawada Assessee By : Shri C.R. Hemanth Kumar, Ca Revenue By : Dr. Aparna Villuri, Sr. Ar

28(iv) of the Act being the pro-rata amount spent by M/s Asian Paints Ltd. on the assessee. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee. Being aggrieved, the assessee is in appeal before us. 10. During the hearing, the learned AR submitted that for the year under consideration, the limitation period available

SRI DHARIPALLI SAMPATH,,WRANGAL vs. ACIT,CENTRAL CIRCLE-2,, VISAKHAPATNAM

In the result, the appeals of the assessee for the A

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

28,000 Visakhapatnam Total 78,000 Total Deposits for the F.Ys. 2005-06 to 2011-12 relevant to A.Ys. 2006-07 1,31,97,730 to 2012-13 The AO called for explanation from the assessee to explain the sources of cash deposits through the notices, reminders and letters, but no compliance was made by the assessee. Therefore

SRI DHARIPALLI SAMPATH,,WARANGAL vs. ACIT, CENTRAL CIRCLE-2,, VISAKHAPATNAM

In the result, the appeals of the assessee for the A

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

28,000 Visakhapatnam Total 78,000 Total Deposits for the F.Ys. 2005-06 to 2011-12 relevant to A.Ys. 2006-07 1,31,97,730 to 2012-13 The AO called for explanation from the assessee to explain the sources of cash deposits through the notices, reminders and letters, but no compliance was made by the assessee. Therefore

SRI DHARIPALLI SAMPATH,, WRANGAL,WRANGAL vs. ACIT, CENTRAL CIRCLE-2,, VISAKHAPATNAM

In the result, the appeals of the assessee for the A

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

28,000 Visakhapatnam Total 78,000 Total Deposits for the F.Ys. 2005-06 to 2011-12 relevant to A.Ys. 2006-07 1,31,97,730 to 2012-13 The AO called for explanation from the assessee to explain the sources of cash deposits through the notices, reminders and letters, but no compliance was made by the assessee. Therefore

SRI DHARIPALLI SAMPATH,, ,WRANGAL vs. ACIT, CENTRAL CIRCLE-2, , VISAKHAPATNAM

In the result, the appeals of the assessee for the A

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

28,000 Visakhapatnam Total 78,000 Total Deposits for the F.Ys. 2005-06 to 2011-12 relevant to A.Ys. 2006-07 1,31,97,730 to 2012-13 The AO called for explanation from the assessee to explain the sources of cash deposits through the notices, reminders and letters, but no compliance was made by the assessee. Therefore

SRI DHARIPALLI SAMPATH,,WRANGAL vs. ACIT, CENTRAL CIRCLE-2,, VISAKHAPATNAM

In the result, the appeals of the assessee for the A

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

28,000 Visakhapatnam Total 78,000 Total Deposits for the F.Ys. 2005-06 to 2011-12 relevant to A.Ys. 2006-07 1,31,97,730 to 2012-13 The AO called for explanation from the assessee to explain the sources of cash deposits through the notices, reminders and letters, but no compliance was made by the assessee. Therefore

SRI DHARIPALLI SAMPATH,,,WRANGAL vs. ACIT, CENTRAL CIRCLE-2,, VISAKHAPATNAM

In the result, the appeals of the assessee for the A

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

28,000 Visakhapatnam Total 78,000 Total Deposits for the F.Ys. 2005-06 to 2011-12 relevant to A.Ys. 2006-07 1,31,97,730 to 2012-13 The AO called for explanation from the assessee to explain the sources of cash deposits through the notices, reminders and letters, but no compliance was made by the assessee. Therefore

SRI DHARIPALLI SAMPATH,,WRANGAL vs. ACIT, CENTRAL CIRCLE-2,, VISAKHAPATNAM

In the result, the appeals of the assessee for the A

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

28,000 Visakhapatnam Total 78,000 Total Deposits for the F.Ys. 2005-06 to 2011-12 relevant to A.Ys. 2006-07 1,31,97,730 to 2012-13 The AO called for explanation from the assessee to explain the sources of cash deposits through the notices, reminders and letters, but no compliance was made by the assessee. Therefore

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)

28 wherein the Ld.AO has sent a draft assessment order for the A.Y. 2013-14 to A.Y. 2019-20 to the JCIT, Central Range, Guntur for approval under section 153D of the Act on 29.09.2021. He further submitted that the JCIT on the same date i.e on 29.09.2021 granted approval in the mechanical manner which is available in the paper

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)

28 wherein the Ld.AO has sent a draft assessment order for the A.Y. 2013-14 to A.Y. 2019-20 to the JCIT, Central Range, Guntur for approval under section 153D of the Act on 29.09.2021. He further submitted that the JCIT on the same date i.e on 29.09.2021 granted approval in the mechanical manner which is available in the paper

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)

28 wherein the Ld.AO has sent a draft assessment order for the A.Y. 2013-14 to A.Y. 2019-20 to the JCIT, Central Range, Guntur for approval under section 153D of the Act on 29.09.2021. He further submitted that the JCIT on the same date i.e on 29.09.2021 granted approval in the mechanical manner which is available in the paper