CHODAY JANAKI RAMAYYA CHOWDARY,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1, KAKINADA

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

Bench: Shri Ravish Sood, Hon’Ble

section 149(1)(b) of the Act. For the sake of clarity, i deem it apposite to cull out the observations of the Hon’ble High Court, as under:- Page. No 13 I.T.A.No.623/VIZ/2025 Choday Janaki Ramayya Chowdary “53. The position of law which can be derived based on the above discussion may be summarized thus: (i)s. 149(1

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.

1) or sub- section (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

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.

1) or sub- section (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

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.

1) or sub- section (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

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

1) or sub- section (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:

1) or sub- section (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 :

1) or sub- section (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

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

1) or sub- section (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

1) or sub- section (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

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:

1) or sub- section (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

MARIA ROJALU POTHAKAMURI,NARSARAOPETA vs. INCOME-TAX OFFICER, WARD-1, NARSARAOPETA

In the result, appeal of the assessee is allowed

Bench: Ld. CIT(A). Before Ld. CIT(A), assessee has raised various grounds challenging the assessment order. After considering the submissions of the assessee, Ld.CIT(A) dismissed the appeal of the assessee. 4. Being aggrieved by the order of the Ld. CIT(A), assessee filed an appeal before the Tribunal by raising following grounds of

46. The ingredients of the proviso could be broken down for analysis as follows: (i) no notice under section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because

AGRI GOLD FOODS AND FARM PRODUCTS LIMITED,VIJAYAWADA vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

Bench: Us:

1) of the Act. 8. During the course of reassessment proceedings, the A.O. observed that the assessee had, in the subject year, transferred certain agricultural land to its subsidiary company, but thereafter had separated both the sale proceeds of the said agricultural land along with its cost from the credit and debit side of its Profit and Loss account

BHARGAV RAM MUNAGAPATI,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-2(1), VIJAYAWADA

In the result, appeal of the assessee is allowed

46. The ingredients of the proviso could be broken down for analysis as follows: (i) no notice under section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because

SUDHARANI SURISETTY,VISAKHAPATNAM vs. INCOME-TAX OFFICER, WARD - 1(1),, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.166/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Sudharani Surisetty V. Income Tax Officer – Ward – 1 29-2-34, Opposite Judge Court Flat No. 401, 4Th Floor Main, Dabagardens Prathyakshar Bhawan Prakasharaopeta Mvp Double Road Visakhapatnam – 530020 Visakhapatnam – 530020 Andhra Pradesh Andhra Pradesh [Pan:Cnbps4046N] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Subrahmanyam, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparnavilluri, Sr.Ar

46,434/- were inflated to Rs. 51,64,300/- due to erroneousinclusion of opening balance (Rs. 2,17,866/-), leading to incorrectapplication of section 149(1)(b). 5. Without prejudice to the above, the Ld. CIT(A), despite all evidences being on record, ought to have adjudicated on merits instead of remanding the matter to the AO. 6. The appellant

MUDUNURI VENKATA SUBBARAJU,WEST GODAVARI vs. INCOME TAX OFFICER, WARD-1, TANUKU

In the result, appeal of the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.284/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Mudunuri Venkata Subbaraju V. Income Tax Officer – Ward – 1 5-205/2, Dommeru Aayakar Bhavan, 35-29-2 Near Reliance Tower Sajjapuram, Tanuku – 534211 Gowthaminagar S.O. Andhra Pradesh Kovvur, West Godavari – 534350 Andhra Pradesh [Pan:Cupps3676D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Subrahmanyam, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr.Ar

46. The ingredients of the proviso could be broken down for analysis as follows: (i) no notice under section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because

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

46,000 Visakhapatnam Total 9,86,500 Financial Year 2010-11 relevant to A.Y. 2011-12 D. Sampath Development Credit Bank, 07211300012926 73,000 S.R. Nagar, Hyderabad D. Sampath Oriental Bank of Commerce, 10812010003930 27,000 Kukatpally, Hyderabad D. Sampath Andhra Bank, Sanath Nagar, 05261001104612 49,000 Hyderabad D. Sampath Axis Bank, Narasaraopet 193010100133074 3,98,000 D. Sampath Axis

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

46,000 Visakhapatnam Total 9,86,500 Financial Year 2010-11 relevant to A.Y. 2011-12 D. Sampath Development Credit Bank, 07211300012926 73,000 S.R. Nagar, Hyderabad D. Sampath Oriental Bank of Commerce, 10812010003930 27,000 Kukatpally, Hyderabad D. Sampath Andhra Bank, Sanath Nagar, 05261001104612 49,000 Hyderabad D. Sampath Axis Bank, Narasaraopet 193010100133074 3,98,000 D. Sampath Axis

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

46,000 Visakhapatnam Total 9,86,500 Financial Year 2010-11 relevant to A.Y. 2011-12 D. Sampath Development Credit Bank, 07211300012926 73,000 S.R. Nagar, Hyderabad D. Sampath Oriental Bank of Commerce, 10812010003930 27,000 Kukatpally, Hyderabad D. Sampath Andhra Bank, Sanath Nagar, 05261001104612 49,000 Hyderabad D. Sampath Axis Bank, Narasaraopet 193010100133074 3,98,000 D. Sampath Axis

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

46,000 Visakhapatnam Total 9,86,500 Financial Year 2010-11 relevant to A.Y. 2011-12 D. Sampath Development Credit Bank, 07211300012926 73,000 S.R. Nagar, Hyderabad D. Sampath Oriental Bank of Commerce, 10812010003930 27,000 Kukatpally, Hyderabad D. Sampath Andhra Bank, Sanath Nagar, 05261001104612 49,000 Hyderabad D. Sampath Axis Bank, Narasaraopet 193010100133074 3,98,000 D. Sampath Axis