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

reassess " to completed assessment proceedings. (vi) Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under section 153A merges into one. Only one assessment shall be made separately for each assessment year on the basis of the findings of the search and any other material existing or brought on the record

KAKARLA GUNA VIDYA SARASWATHI,,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, WARD-1(2), , VISAKHAPATNAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.177/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Smt.Kakarla Guna Vidya Saraswathi Vs. Income Tax Officer C/O Kakrla Surya Gangadhar Tilak Ward-3(3) A-1, Janani Apartments Visakhapatnam Pandurangaswamy Temple Backside Pandurangapuram Visakhapatnam [Pan : Apjpk5999N] आयकर अपील सं./I.T.A.No.178/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Sri Kakarla Surya Gangadhar Tilak Vs. Income Tax Officer A-1, Janani Apartments Ward-1(2) Pandurangaswamy Temple Backside Visakhapatnam Pandurangapuram Visakhapatnam [Pan : Ahbpk5319G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri I.Kama Sastry, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 27.02.2023 घोर्णध की तधरीख/Date Of Pronouncement : 31.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)]-1 Visakhapatnam

reassessment. (iv) The onus is on the Revenue to show that proper service of notice has been effected under section 148 of the Act on the Assessee or an agent duly empowered by him to accept notices on his behalf. In the present case, the Revenue has failed to discharge that onus. On the facts of the present case

KAKRLA SURYA GANGADHAR TILAK,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, WARD-3(3), , VISAKHAPATNAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.177/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Smt.Kakarla Guna Vidya Saraswathi Vs. Income Tax Officer C/O Kakrla Surya Gangadhar Tilak Ward-3(3) A-1, Janani Apartments Visakhapatnam Pandurangaswamy Temple Backside Pandurangapuram Visakhapatnam [Pan : Apjpk5999N] आयकर अपील सं./I.T.A.No.178/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Sri Kakarla Surya Gangadhar Tilak Vs. Income Tax Officer A-1, Janani Apartments Ward-1(2) Pandurangaswamy Temple Backside Visakhapatnam Pandurangapuram Visakhapatnam [Pan : Ahbpk5319G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri I.Kama Sastry, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 27.02.2023 घोर्णध की तधरीख/Date Of Pronouncement : 31.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)]-1 Visakhapatnam

reassessment. (iv) The onus is on the Revenue to show that proper service of notice has been effected under section 148 of the Act on the Assessee or an agent duly empowered by him to accept notices on his behalf. In the present case, the Revenue has failed to discharge that onus. On the facts of the present case

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

reassessment proceedings,\nand the claim was new and not previouslydeclared, and but in\npresent case ie.., gowripatnam primary agricultural cooperative\ncredit society limited, the return was filed in response to a valid\nPage. No 4\nI.T.A.Nos.432, 433 & 434/VIZ/2025\nGowripatnam Primary Agricultural Cooperative\nCredit Society Limited --\nnoticeu/s 148, which reopens the assessment and allows a\nreassessment of total incomeincluding

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

reassessment proceedings,\nand the claim was new and not previouslydeclared, and but in\npresent case ie.., gowripatnam primary agricultural cooperative\ncredit society limited, the return was filed in response to a valid\nnoticeu/s 148, which reopens the assessment and allows a\nreassessment of total incomeincluding all deductions under\n80P(2)(a)(i) of the Income

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

reassessment proceedings,\nand the claim was new and not previouslydeclared, and but in\npresent case ie.., gowripatnam primary agricultural cooperative\ncredit society limited, the return was filed in response to a valid\nnoticeu/s 148, which reopens the assessment and allows a\nreassessment of total incomeincluding all deductions under\n80P(2)(a)(i) of the Income

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

96,69,291 85,34,11,142 13,98,37,651 4. The Ld. AO also disallowed depreciation amounting to Rs.6,36,87,756/- on the bogus plant and machinery claimed by the assessee. Further, the Ld. AO also observed differences in stock wherein the excess stock was valued at Rs. 1,83,46,348/- and deficit stock was valued

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

96,69,291 85,34,11,142 13,98,37,651 4. The Ld. AO also disallowed depreciation amounting to Rs.6,36,87,756/- on the bogus plant and machinery claimed by the assessee. Further, the Ld. AO also observed differences in stock wherein the excess stock was valued at Rs. 1,83,46,348/- and deficit stock was valued

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

96,69,291 85,34,11,142 13,98,37,651 4. The Ld. AO also disallowed depreciation amounting to Rs.6,36,87,756/- on the bogus plant and machinery claimed by the assessee. Further, the Ld. AO also observed differences in stock wherein the excess stock was valued at Rs. 1,83,46,348/- and deficit stock was valued

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

96,69,291 85,34,11,142 13,98,37,651 4. The Ld. AO also disallowed depreciation amounting to Rs.6,36,87,756/- on the bogus plant and machinery claimed by the assessee. Further, the Ld. AO also observed differences in stock wherein the excess stock was valued at Rs. 1,83,46,348/- and deficit stock was valued

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

96,69,291 85,34,11,142 13,98,37,651 4. The Ld. AO also disallowed depreciation amounting to Rs.6,36,87,756/- on the bogus plant and machinery claimed by the assessee. Further, the Ld. AO also observed differences in stock wherein the excess stock was valued at Rs. 1,83,46,348/- and deficit stock was valued

GEDDA APPA RAO,UNDI vs. INCOME TAX OFFICER, WARD-1, BHIMAVARAM

In the result, appeal of the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.183/Viz/2023 (ननधधारण वर्ा / Assessment Year :2013-14) Gedda Appa Rao Vs. Income Tax Officer D.No.2-67, Sitaram Pet Ward-1 Undi Bhimavaram [Pan : Axopg9721M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : None प्रत्यधथी की ओर से / Respondent By : Shri Madhukar Aves, Dr सुनवधई की तधरीख / Date Of Hearing : 06.09.2023 घोर्णध की तधरीख/Date Of Pronouncement : 18.10.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: This Appeal Is Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeal) [Cit(A)], National Faceless Appeal Centre (Nfac), Delhi Vide Din & Order No. Itba/Nfac/S/250/2023- 24/1053170768(1) Dated 25.05.2023 Arising Out Of The Assessment Order Passed U/S 143(3) R.W.S.147 Of The Income Tax Act, 1961 (In Short “Act”) Dated 11.12.2017 For The Assessment Year (A.Y.)2013-14. 2. Brief Facts Of The Case Are That The Assessee, An Individual Has Not Filed Any Return Of Income For A.Y.2013-14. The Ao Reopened The Case U/S 147 Of The Act On The Basis Of Information With Respect To Cash Deposit In 2

96,280/- as gross total income in response to notice u/s 148 on 28.09.2016. The Assessing Officer (AO) noted that there was total cash deposit of Rs.32,12,000/- in assessee’s bank account. When the assessee was asked to explain the sources for the cash deposit, the assessee explained that the assessee received 1/4th of his share of Rs.2

SRINIVASA RAO ARNEPALLI,KRISHNA DIST vs. PRINCIPAL COMMISSIONER OF INCOME TAX, VIJAYAWADA

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.153/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2017-18) Srinivasa Rao Arnepalli Vs. Principal Commissioner Of Bhavishya Edible Oil Refinery Income Tax 140/1, Kodurupadu Vijayawada Bapulapadu Mandalam Krishna Dist. [Pan : Aftpa9285K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

96,817/- and the Ld. AO examined the loan interest certificate submitted by the assessee before the Ld. AO and hence it is not correct to state that proper verification has not been carried on by the AO. 5 I.T.A. No.153/Viz/2023, A.Y.2017-18 Sinivasa Rao Arnepalli, Krishna Dist. 5. On the facts and in the circumstances of the case

VISWAMANAVA SAMAIKYATA SAMSAT,GUNTUR vs. INCOME TAX OFFICER(EXEMPTIONS), GUNTUR

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No. 278/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2014-15) M/S. Viswamanava Samikyata Vs. Income Tax Officer Samsat, Guntur. (Exemptions), Pan: Aaatv 1597 P Guntur. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessee By : Sri Gvn Hari, Advocate प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 02/04/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R

reassessment proceedings as void ab initio. 4. Without prejudice to Ground No.2, the Ld. CIT(A) is not justified in upholding the addition of Rs. 4,20,54,192/- made by the AO by disallowing of the exemption claimed U/s. 11(1)(d) of the Act by the appellant in respect of the corpus donations. 5. Without prejudice to Ground