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

56,720/- 7. The assessee firm, being aggrieved with the order of the CIT(A), has carried the matter in appeal before us. 8. We have heard the Learned Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service

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**

56 of the Act and not eligible for deduction under section 80P of the Act. - **6.** On being aggrieved, assessee filed an appeal before Ld. CIT(A). Ld.CIT(A) sustained the order of the Ld. AO. - **7.** On being aggrieved by the order of the Ld. CIT(A), assessee is in appeal before us by raising following grounds of appeal

KUMAR PAPPU SINGH,TANUKU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.270/Viz/2018 (धििाारण िर्ा/Assessment Year:2013-2014) Sri Kumar Pappu Singh Vs. Dy.Commissioner Of D.No.23-3-26, Sundaram Nagar Income Tax, Sajjapuram Circle-1, Kks Towers, Tanuku Rr Pet, Eluru [Pan : Aeepp2496P] Andhra Pradesh (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

1,00,000 100 10,000,000 From the above details it is established that the company is closely held company and all the shareholders are legal ascendants or descendants as defined in the Act under close relatives. For ready reference the definition of close relative given in the act under section 56

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

section 149(1)(b) are not applicable. Judicially following the principles laid down by the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT (surpa), we are of the considered opinion that the reassessment notice issued by the Ld. AO is not in conformity with the provisions of the Act and hence

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

section 149(1)(b) are not applicable. Judicially following the principles laid down by the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT (surpa), we are of the considered opinion that the reassessment notice issued by the Ld. AO is not in conformity with the provisions of the Act and hence

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

section 149(1)(b) are not applicable. Judicially following the principles laid down by the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT (surpa), we are of the considered opinion that the reassessment notice issued by the Ld. AO is not in conformity with the provisions of the Act and hence

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

section 149(1)(b) are not applicable. Judicially following the principles laid down by the Hon’ble Karnataka High Court in the case of Novo Nordisk India (P.) Ltd vs. DCIT (surpa), we are of the considered opinion that the reassessment notice issued by the Ld. AO is not in conformity with the provisions of the Act and hence

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

Bench: Us:

56,79,202 Balance of land value as on 31.03.2007 Rs.4,86,58,293 …………….x……………x………….. 5.4 1. As per explanation of appellant, the cost of land transferred to M/s. Harithasadhana Projects Pvt. Ltd. was Rs.1,59,53,391/- out of the total deletion of fixed assets (land block) of Rs 2.56,79,202/- during the relevant Assessment Year

GUNTUPALLI NAGESWARA RAO,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 1(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

reassessment notice is issued for less than Rs.50 lacks escaped income for the period beyond 3 years. 3. The Ld. CIT(A) NFAC erred both on facts and in law in upholding the disallowance of deductions under Chapter VIA of Rs.3,84,267/- made vide assessment order passed u/s.147 without appreciating the facts and the evidences. 4. Any other ground/grounds

GUNTUPALLI NAGESWARA RAO,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 1(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

reassessment notice is issued for less than Rs.50 lacks escaped income for the period beyond 3 years. 3. The Ld. CIT(A) NFAC erred both on facts and in law in upholding the disallowance of deductions under Chapter VIA of Rs.3,84,267/- made vide assessment order passed u/s.147 without appreciating the facts and the evidences. 4. Any other ground/grounds

ANDHRA PRADESH CAPITAL REGION DEVELOPMENT AUTHORITY,,VIJAYAWADA vs. ACIT, CIRCLE-3(1),, VIJAYAWADA

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleandhra Pradesh Capital Vs. Acit, Circle-3(1), Region Development Authority Vijayawada. (Formerly Vgtm Urban Development Authority), Uda Complex, Lenin Centre, Governorpet, Vijayawada. Pan No. Aaalv 0067 E (Appellant) (Respondent)

section 147 it is clear that there should a „reason‟ and „belief‟ and such reasons must be recorded. The assessee must have disclosed fully and truly all material facts necessary for his assessment for that (A.P. Capital Region Development Authority) assessment year. Here in the case on hand, the then Assessing Officer has rightly recorded his reasons believed. Basing

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

56,34,856/- and added back to the total income of the assessee. 7 6. The Ld. AO also made disallowance U/s. 14A of the Act to the extent of Rs.19,27,456/- having not satisfied with the assessee’s explanation that though the assessee made investments in certain companies which was made in the earlier years and no dividend

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

56,34,856/- and added back to the total income of the assessee. 7 6. The Ld. AO also made disallowance U/s. 14A of the Act to the extent of Rs.19,27,456/- having not satisfied with the assessee’s explanation that though the assessee made investments in certain companies which was made in the earlier years and no dividend

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

56,34,856/- and added back to the total income of the assessee. 7 6. The Ld. AO also made disallowance U/s. 14A of the Act to the extent of Rs.19,27,456/- having not satisfied with the assessee’s explanation that though the assessee made investments in certain companies which was made in the earlier years and no dividend

DWARAMPUDI KRSS SUBBIREDDY L/R OF DWARAMPUDI RAMAKRISHNA REDDY,EAST GODAVARI DIST vs. INCOME TAX OFFICER, WARD-2, KAKINADA

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

Bench: Us:

56,309/- but the said explanation did not find favour with the A.O. Accordingly, the A.O. determined the income vide his order passed u/s 144 of the Act, dated 21.12.2019 at Rs. 15,04,580/-. 4 Dwarampudi K R S S Subbireddy, L/R of Dwarampudi Ramakrishna Reddy, 4. Aggrieved, an appeal was filed against the order passed

KUNUMURI KRISHNA KUMARI,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

56,410 2,07,790 6,36,620 K.Krishna 6,17,860 2,30,710 7,10,260 Kumari 4.1 Subsequently, the assessees have filed the revised returns of income for the A.Y. 2009-10 on 30.03.2012 as per the details given below : Name of the appellant AY.2009-10 K.Subba Raju 1,42,270 K.Lakshmii Sirisha 80,260 S.Raja Ramesh

KANUMURI SIVA RAMA RAJU,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

56,410 2,07,790 6,36,620 K.Krishna 6,17,860 2,30,710 7,10,260 Kumari 4.1 Subsequently, the assessees have filed the revised returns of income for the A.Y. 2009-10 on 30.03.2012 as per the details given below : Name of the appellant AY.2009-10 K.Subba Raju 1,42,270 K.Lakshmii Sirisha 80,260 S.Raja Ramesh

SAMANTHAPUDI LAVANYA,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

56,410 2,07,790 6,36,620 K.Krishna 6,17,860 2,30,710 7,10,260 Kumari 4.1 Subsequently, the assessees have filed the revised returns of income for the A.Y. 2009-10 on 30.03.2012 as per the details given below : Name of the appellant AY.2009-10 K.Subba Raju 1,42,270 K.Lakshmii Sirisha 80,260 S.Raja Ramesh

KANUMURI LAKSHMI SIRISHA ,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF I NCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

56,410 2,07,790 6,36,620 K.Krishna 6,17,860 2,30,710 7,10,260 Kumari 4.1 Subsequently, the assessees have filed the revised returns of income for the A.Y. 2009-10 on 30.03.2012 as per the details given below : Name of the appellant AY.2009-10 K.Subba Raju 1,42,270 K.Lakshmii Sirisha 80,260 S.Raja Ramesh