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

56 of the Act and not eligible for\ndeduction under section 80P of the Act.\n6. On being aggrieved, assessee filed an appeal before Ld. CIT(A).\nLd.CIT(A) sustained the order of the Ld. AO.\n7. On being aggrieved by the order of the Ld. CIT(A), assessee is in appeal\nbefore us by raising following grounds of appeal

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

56 of the Act and not eligible for\ndeduction under section 80P of the Act.\n6. On being aggrieved, assessee filed an appeal before Ld. CIT(A).\nLd.CIT(A) sustained the order of the Ld. AO.\n7. On being aggrieved by the order of the Ld. CIT(A), assessee is in appeal\nbefore us by raising following grounds of appeal

GOWRIPATNAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,GOWRIPATNAM vs. ITO, WARD-1, TADEPALLIGUDEM

56 of the Act and not eligible for\ndeduction under section 80P of the Act.\n6.\nOn being aggrieved, assessee filed an appeal before Ld. CIT(A).\nLd.CIT(A) sustained the order of the Ld. AO.\n7.\nOn being aggrieved by the order of the Ld. CIT(A), assessee is in appeal\nbefore us by raising following grounds of appeal

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

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

2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident under section 163 and the assessment, reassessment or recomputation to be made

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

2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident under section 163 and the assessment, reassessment or recomputation to be made

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

2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident under section 163 and the assessment, reassessment or recomputation to be made

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

2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident under section 163 and the assessment, reassessment or recomputation to be made

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

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 2

SAMANTHAPUDI RAJA RAMESH,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 2

KANUMURI LAKSHMI UMA KATYAINI ,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 2

KANUMURI LAKSHMI UMA KATYAINI ,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 2

SAMANTHAPUDI RAJA RAMESH ,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 2

KANUMURI PRASAD,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 2

KANUMURI PRASAD,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 2