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.

45,000/-; AND (B). Flat No. 402, Roshini Residency, Bakkannapalem, Visakhapatnam for a purchase consideration of RS. 17,54,030/-, viz. (i). purchase consideration vide a registered document No.2888/2017, dated 21/06/2017: Rs. 13,03,000/-; (ii). registration expenses: Rs. 98,030/-; and (iii). payment towards execution of construction works: Rs. 3,53,000/-. 8. Apart from that, the AO observed

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.

45,000/-; AND (B). Flat No. 402, Roshini Residency, Bakkannapalem, Visakhapatnam for a purchase consideration of RS. 17,54,030/-, viz. (i). purchase consideration vide a registered document No.2888/2017, dated 21/06/2017: Rs. 13,03,000/-; (ii). registration expenses: Rs. 98,030/-; and (iii). payment towards execution of construction works: Rs. 3,53,000/-. 8. Apart from that, the AO observed

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.

45,000/-; AND (B). Flat No. 402, Roshini Residency, Bakkannapalem, Visakhapatnam for a purchase consideration of RS. 17,54,030/-, viz. (i). purchase consideration vide a registered document No.2888/2017, dated 21/06/2017: Rs. 13,03,000/-; (ii). registration expenses: Rs. 98,030/-; and (iii). payment towards execution of construction works: Rs. 3,53,000/-. 8. Apart from that, the AO observed

DASARI SAI ANNAPURNA L/R OF LATE DASARI GOPI KRISHNA REDDY,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), VIJAYAWADA, VIJAYAWADA

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

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.583/Viz/2025 (िनधा"रण वष"/Assessment Year:2015-16) Dasari Sai Annapurna Vs. Assistant Commissioner L/R Of Late Dasari Gopi Of Income Tax, Krishna Reddy, Central Circle-2(1), Vijayawada. Vijayawada. Pan: Aeipd0990C (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Mv Prasad, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 27/11/2025 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 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 (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 28/03/2022, For The Assessment Year 2015-16. The 2 Dasai Sai Annapurna L/R Of Late Dasari Gopi Krishna Reddy Vs. Acit

45 r.w.s 2(47)(v) of the Act 4 Dasai Sai Annapurna L/R of Late Dasari Gopi Krishna Reddy vs. ACIT was though statutorily obligated to disclose “capital gains” on te aforesaid transaction during the subject year after taking into consideration the cost of acquisition of land vis-à-vis sale value of 8 flats that were to be received

LATE AT RAYUDU INDIVIDUAL REPRESENTATIVE BY AVINASH ,VISAKHAPATNAM vs. THE COMMISSIONER OF INCOME TAX, APPEALS-3,, VISAKHAPATNAM

In the result, appeal filed by the assessee is dismissed

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

45% of the shares in the company as deemed dividend U/s. 2(22)(e) of the Act. Accordingly, the Ld. AO assessed the income at Rs.1,94,43,992/-. Aggrieved by the order of the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). 4. The Ld. CIT(A) considering the submissions made by the assessee

A.TIRUPATHI RAYUDU(HUF),VISAKHAPATNAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, VISAKHAPATNAM

In the result, appeal filed by the assessee dismissed

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

45% of the shares in the company as deemed dividend U/s. 2(22)(e) of the Act. Accordingly, the Ld. AO assessed the income at Rs.1,94,43,992/-. Aggrieved by the order of the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). 4. The Ld. CIT(A) considering the submissions made by the assessee

LATE AT RAYUDU INDIVIDUAL REPRESENTATIVE BY AVINASH ,VISAKHAPATNAM vs. THE COMMISSIONER OF INCOME TAX, APPEALS-3, , VISAKHAPATNAM

In the result, appeal filed by the assessee is dismissed

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

45% of the shares in the company as deemed dividend U/s. 2(22)(e) of the Act. Accordingly, the Ld. AO assessed the income at Rs.1,94,43,992/-. Aggrieved by the order of the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). 4. The Ld. CIT(A) considering the submissions made by the assessee

YALAMANCHILI NEELIMA,,GUNTUR vs. THE INCOME TAX OFFICER, WARD-2(2),, GUNTUR

In the result, appeal of the assessee is partly allowed for statistical purposes

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

2. The Ld. CIT(A) ought to have quashed the notice issued U/s. 148 of the Act and further he ought to have held that the reassessment proceedings are liable to be quashed as void ab initio. Without prejudice to the above: 3. The Ld. CIT(A) is not justified in confirming the addition

SATYA VENKATA KRISHNA RAVI PRASAD KODURI,RAJAHMUNDRY vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

reassessed or recomputed in a\npreceding order”\n10. She also reiterated in her written submissions the various scenario under\nwhich the penalty under section 270A leviable, which is reproduced below: -\nScenarios\na.\nApplicability for assessee's case\nNot Applicable since there is no\ndifference between assessed income and\nreturned income\nwhen the assessed income is\ngreater than the returned income

SATYA VENKATA KRISHNA RAVI PRASAD KODURI,EAST GODHAVARI vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

reassessed or recomputed in a\npreceding order”\n10.\nShe also reiterated in her written submissions the various scenario under\nwhich the penalty under section 270A leviable, which is reproduced below: -\na.\nScenarios\nwhen the assessed income is\ngreater than the returned income;\n(refer 270A(2))\nb.\nwhere return was filed and\nassessed income is more than\nincome

VEERA VENKATA RAMAKRISHNA MOHAN RAO KODURI,EAST GODHAVARI vs. ACIT, CIRLCE - 1, RAJAHMUNDRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita Nos. 290 & 291/Viz/2025 निर्धारण वर्ा/ Assessment Years:2018-19 & 2019-20) Veera Venkata Ramakrishna V. Acit – Circle – 1 Mohana Rao Koduri Ayakkar Bhawan Flat No. 201, Sri Towers Nh-16 Veerabadhrapuram Venkateswara Nagar Rajahmundry – 533105 Syamalanagar Andhra Pradesh East Godavari District - 533103 Andhra Pradesh [Pan:Afrpk0888C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita Nos. 293 & 294/Viz/2025 निर्धारणवर्ा/ Assessment Years:2018-19 & 2019-20) Satya Venkata Krishna Ravi V. Acit – Circle – 1 Prasad Koduri Ayakkar Bhawan 81-10-3/6, Venkateswaranagar Veerabadhrapuram Near Ima Halla, Danavaipeta Rajahmundry – 533105 East Godavari District Andhra Pradesh Andhra Pradesh [Pan:Afrpk0889D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt Hemalatha K, Ca राजस्व का प्रतततितित्व/ Department Represented By : Shri Badicala Yadagiri, Cit(Dr)

reassessed or recomputed in a preceding order” 10. She also reiterated in her written submissions the various scenario under which the penalty under section 270A leviable, which is reproduced below: - Scenarios Applicability for assessee’s case a. when the assessed income is Not Applicable since there is no greater than the returned income; difference between assessed income and (refer 270A

VEERA VENKATA RAMAKRISHNA MOHANA RAO KODURI,RAJAHMUNDRY vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita Nos. 290 & 291/Viz/2025 निर्धारण वर्ा/ Assessment Years:2018-19 & 2019-20) Veera Venkata Ramakrishna V. Acit – Circle – 1 Mohana Rao Koduri Ayakkar Bhawan Flat No. 201, Sri Towers Nh-16 Veerabadhrapuram Venkateswara Nagar Rajahmundry – 533105 Syamalanagar Andhra Pradesh East Godavari District - 533103 Andhra Pradesh [Pan:Afrpk0888C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita Nos. 293 & 294/Viz/2025 निर्धारणवर्ा/ Assessment Years:2018-19 & 2019-20) Satya Venkata Krishna Ravi V. Acit – Circle – 1 Prasad Koduri Ayakkar Bhawan 81-10-3/6, Venkateswaranagar Veerabadhrapuram Near Ima Halla, Danavaipeta Rajahmundry – 533105 East Godavari District Andhra Pradesh Andhra Pradesh [Pan:Afrpk0889D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt Hemalatha K, Ca राजस्व का प्रतततितित्व/ Department Represented By : Shri Badicala Yadagiri, Cit(Dr)

reassessed or recomputed in a preceding order” 10. She also reiterated in her written submissions the various scenario under which the penalty under section 270A leviable, which is reproduced below: - Scenarios Applicability for assessee’s case a. when the assessed income is Not Applicable since there is no greater than the returned income; difference between assessed income and (refer 270A

VENKATA RAMANAIAH KOPPARAPU,SATTEPALLI vs. INCOME-TAX OFFICER, GUNTUR

In the result, appeal of the assessee is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.317/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2016-17) Venkata Ramanaiah Kopparapu V. Income Tax Officer C.R. Buildings D.No. 18-9-10/2, Atchampeta Road Kannavarithota, Guntur – 522001 Near Sisuvihar, Sattenapalli-522403 Andhra Pradesh Andhra Pradesh [Pan: Dhmpk6477H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

45,500/- in State Bank of Hyderabad, Gunfoundary Branch and State bank of Hyderabad, Sathenpalle Branch, respectively during the impugned assessment year. Since assessee has not filed return of income, notice under section 142(1) of the Act was issued to the assessee on 2.08.2023 and 11.12.2023. In response, assessee furnished reply along with copy of bank statements. Assessee further

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISAKHAPATNAM vs. ANUMOLU TIRUPATI RAYUDU(HUF),, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

45% of share holding in the company. The case was selected for scrutiny and the assessment was completed U/s. 143(3) on 28/02/2014 and the income was determined at Rs. 40,12,785/- and a tax demand of Rs. 2,00,310/- was raised. Thereafter, a search and seizure operations U/s. 132 of the Act were conducted on 14/10/2015

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

45% of share holding in the company. The case was selected for scrutiny and the assessment was completed U/s. 143(3) on 28/02/2014 and the income was determined at Rs. 40,12,785/- and a tax demand of Rs. 2,00,310/- was raised. Thereafter, a search and seizure operations U/s. 132 of the Act were conducted on 14/10/2015

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

45% of share holding in the company. The case was selected for scrutiny and the assessment was completed U/s. 143(3) on 28/02/2014 and the income was determined at Rs. 40,12,785/- and a tax demand of Rs. 2,00,310/- was raised. Thereafter, a search and seizure operations U/s. 132 of the Act were conducted on 14/10/2015

ARRDY ENGINEERING INNOVATIONS PVT LTD,ODISHA vs. ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-1(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.307 & 308/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2012-13 & 2013-14) M/S. Arrdy Engineering Innovations (P.) Ltd., V. Asst. Cit – Circle – 1(1) Bb-8 Area 7 & 8 Income Tax Office Civil Township, Rourkela – 769004 Direct Tax Building, Mvp Colony Visakhapatnam – 530017 Odisha Andhra Pradesh [Pan: Aabca4800A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

45,70,738 under Page No. 2 I.T.A.Nos.307 & 308/VIZ/2023 M/s. Arrdy Engineering Innovations (P.) Ltd., section 35(2AB) of the Act. Assessing Officer also noticed that assessee has received a grant of Rs.50,00,000/- from DSIR during the year. Therefore, he concluded that assessee is eligible for deduction on the balance expenditure

AARDY ENGINEERING INNOVATION PVT LTD,ODISHA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.307 & 308/Viz/2023 (निर्धारण वर्ा/ Assessment Years: 2012-13 & 2013-14) M/S. Arrdy Engineering Innovations (P.) Ltd., V. Asst. Cit – Circle – 1(1) Bb-8 Area 7 & 8 Income Tax Office Civil Township, Rourkela – 769004 Direct Tax Building, Mvp Colony Visakhapatnam – 530017 Odisha Andhra Pradesh [Pan: Aabca4800A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

45,70,738 under Page No. 2 I.T.A.Nos.307 & 308/VIZ/2023 M/s. Arrdy Engineering Innovations (P.) Ltd., section 35(2AB) of the Act. Assessing Officer also noticed that assessee has received a grant of Rs.50,00,000/- from DSIR during the year. Therefore, he concluded that assessee is eligible for deduction on the balance expenditure

SHAIK SAIDA,NUZVID vs. INCOME TAX OFFICER, WARD-3(1), VIJAYAWADA

In the result, appeal of the assessee is allowed for statistical purposes as indicated herein above

Bench: the Tribunal and the assessee has filed an affidavit explaining the reasons, similar to the three appeals, which are extracted herein below:

45,72,200/- and Rs. 32,02,000/- in the State Bank of India during the year under consideration. However, the assessee has not filed his return of income for the Asst. Year 2015-16. Therefore, case of the assessee was reopened and the order U/s. 148A(d) of the Act was passed on 18/04/2022 and notice