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]

47,000) for payment of purchase consideration for the shares acquired under preferential allotment. This amount and other funds available with the assessee are utilised for acquisition of the shares. Further, assessee submitted that assessee paid Rs.1,91,98,000/- to the Company Steel Exchange India Ltd towards sale consideration for the purchase of 6,62,000 shares allotted

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

47,755/-. 4. Aggrieved, the assessee carried the matter in appeal before the CIT(A). 5. Ostensibly, the assessee had, inter alia, assailed the validity of the jurisdiction that was assumed by the Jurisdictional Assessing Officer (JAO) as against the Faceless Assessing Officer (FAO) as per the scheme framed under section 151A of the Act and notified on 29/03/2022

SIVAKAMA SUNDAR MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

reassessment proceedings, the Ld.AO has considered the date of Joint Development agreement as date of purchase and has computed the capital gains accordingly. The Ld. CIT invoking the powers vested U/s. 263 of the Act considered the order as erroneous and prejudicial to the interest of the Revenue since the Ld. AO has erred in treating the asset as long

VIDYAVATHI MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

reassessment proceedings, the Ld.AO has considered the date of Joint Development agreement as date of purchase and has computed the capital gains accordingly. The Ld. CIT invoking the powers vested U/s. 263 of the Act considered the order as erroneous and prejudicial to the interest of the Revenue since the Ld. AO has erred in treating the asset as long

MURALI MOHAN REDDY BONTHU,VIJAYAWADA vs. INCOME-TAX OFFICER, WARD-3(1), VIJAYAWADA

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.265/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2013-14) Murali Mohan Reddy Bonthu V. Income Tax Officer – Ward – 3(1) 14/4, Flat No. 503 Cr Building, 1St Floor Annex Sree Satya Sai Towers M.G. Road, Vijayawada – 522002 Andhra Pradesh Main Road Nunna Andhra Pradesh - 521212 [Pan:Aiopb5077E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri I. Kama Sastry, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparna Villuri, Sr.Ar

47,200/- by way of sale consideration. Ld. AO considering the assessee has not filed the development agreement denied the exemption claimed by the assessee under section 54F of the Act by making addition of Rs.1,23,53,826/-. 3. On being aggrieved by the order of the Ld. AO, assessee filed an appeal before Ld. CIT(A). Assessee also

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

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

SRI KOTI LINGA HARI HARA MAHAKSHETRAM TEMPLE,VISAKHAPATNAM vs. INCOME TAX OFFICER, EXEMPTION WD, RAJAHMUNDRY

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.365/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Sri Koti Linga Hari Hara Vs. Income Tax Officer, Mahakshetram Temple, Exemption Ward, Visakhapatnam. Rajahmundry. Pan: Acgfs3064C (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Cr Hemanth Kumar, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/11/2025 Hearing: घोषणा की तारीख/Date Of 07/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

reassessment framed on such an incorrect foundation is illegal, void ab initio, and without jurisdiction. 3. The Ld. Commissioner of Income Tax (Appeals) failed to appreciate that the appellant, being a temple governed by the Endowments Department of the Government of Andhra Pradesh, is eligible for exemption u/s 10(23BBA) 3 Sri Koti Linga Hari Hara Mahakshetram Temple

NARASIMHA RAO JAMMIGUMPULA,GUNTUR vs. INCOME TAX OFFICER, NARASARAOPET

In the result, appeal of the assessee is allowed

Bench: the Ld. CIT(A).

47,70,000/- in the SB account of Andhra Bank. Accordingly, on the basis of the information available, notice U/s. 148A(b) of the Act was issued on 21/03/2022 with the prior approval of the competent authority. Thereafter, notice U/s. 148 of the Act dated 07/04/2022 was issued electronically however, there was no response from the assessee. Subsequently, notice

AKUNURI SAI AVINASH,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE (INTERNATIONAL TAXATION), VISAKHAPATNAM

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

Bench: Shri Duvvuru Rl Reddy, Hon‟Ble & Shri S Balakrishnan, Hon‟Bleआयकरअपीलसं./ I.T.A. No.42/Viz/2023 (धनधाारणिर्ा/ Assessment Year : 2016-17) Akunuri Sai Avinash, Vs. The Asst. Commissioner Of Rep. By Gpa Holder Dr. Akunuri Income Tax, Sai Babu, Circle (International Taxation), Visakhapatnam. Visakhapatnam. Pan: (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent) अपीलाथीकीओरसे/ Assessee By : Sri Gvn Hari, Ar प्रत्याथीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुनिाईकीतारीख/ Date Of Hearing : 26/03/2024 घोर्णाकीतारीख/Date Of : 12/04/2024 Pronouncement O R D E R Per S. Balakrishnan:

reassessment proceedings as void ab initio. 3. The Hon’ble Dispute Resolution Panel is not justified in holding that the capital gains are applicable for the subject assessment year 2016-17 in respect of the sale transaction concluded in the FY 2014-15 relevant for AY 2015-16. 4. The Hon’ble Dispute Resolution Panel is not justified in directing

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

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

reassessment after four years of close of relevant assessment year was invalid, the Ld. AR placed heavy reliance on the decision of the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT [2018] 95 taxmann.com 225 (Karnataka). The Ld. AR also referred to the decision of the Hon’ble Allahabad High Court

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

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

reassessment after four years of close of relevant assessment year was invalid, the Ld. AR placed heavy reliance on the decision of the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT [2018] 95 taxmann.com 225 (Karnataka). The Ld. AR also referred to the decision of the Hon’ble Allahabad High Court

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

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

reassessment after four years of close of relevant assessment year was invalid, the Ld. AR placed heavy reliance on the decision of the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT [2018] 95 taxmann.com 225 (Karnataka). The Ld. AR also referred to the decision of the Hon’ble Allahabad High Court

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

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

reassessment after four years of close of relevant assessment year was invalid, the Ld. AR placed heavy reliance on the decision of the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT [2018] 95 taxmann.com 225 (Karnataka). The Ld. AR also referred to the decision of the Hon’ble Allahabad High Court

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

Bench: Us:

reassessment order under Sec. 143(3) r.w.s 147, dated 31.03.2015, inter alia, for the reason that the same had been passed in violation of the mandate of the “1st proviso” of Sec. 147 of the Act. Admittedly, as stated by the Ld. A.R and, rightly so, in a case where an assessment had earlier been made under Section

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

ACIT, CIRCLE-1(1),, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

ACIT, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

THE INCOME TAX OFFICER, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

Bench: Us:

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject