DEPUTY COMMISSIONER OF INCOME TAX (IT), VISAKHAPATNAM vs. SHRI APPARAO MUKKAMALA, USA

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

143 & 147/148. 27. Section 153A and 153C starts with non-obstante clause. The procedure for assessment/reassessment in Section 153A, 153C in cases of search or requisition has an overriding effect to the regular provisions for assessment or reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section

SAI SRI ANUSHA VALLURU,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

U/S 143(3) r.w.s. 147 of the IT Act,\nby the Deputy Commissioner of Income Tax, Circle-2, Vijayawada, dt\n28.12.2016, is erroneous, bad in law, and liable to be quashed.\n2.\nThat the Learned CIT(A) erred in passing an ex-parte order without\ngranting sufficient and proper opportunity of being heard to the appellant,\nthereby violating the principles

INCOME TAX OFFICER, WARD-2(3), VIJAYAWADA vs. SREELAKSHMI MUSUNURU, PENAMALURU

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.278/Viz/2024 (िनधा"रण वष"/Assessment Year: 2013-14) Income Tax Officer, Vs. Sreelakshmi Musunuru, Ward-2(3), Penamaluru. Vijayawada. Pan: Aojpm4884K (Appellant) (Respondent)

Section 143(3) of the Act, dated 16.12.2015 could not have sought to dislodge her concluded assessment after the expiry of a period of four years from the end of the relevant assessment year, i.e., beyond 31.03.2018. 25. Analyzing the scope of the “1st proviso” to Sec. 147 of the Act, which contemplates that where assessment in the assesse

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.

143 or Section 148 or sub- section (1) of Section 153A or sub-section (2) of Section 153C. To sum up, the obligation cast upon an assessee to call in question the jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where he objects to the assumption of jurisdiction

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.

143 or Section 148 or sub- section (1) of Section 153A or sub-section (2) of Section 153C. To sum up, the obligation cast upon an assessee to call in question the jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where he objects to the assumption of jurisdiction

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.

143 or Section 148 or sub- section (1) of Section 153A or sub-section (2) of Section 153C. To sum up, the obligation cast upon an assessee to call in question the jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where he objects to the assumption of jurisdiction

INCOME TAX OFFICER, WARD-1, GUDIWADA vs. CHAGANTIPADU PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LIMITED NOH957, CHAGANTIPADU VILLAGE,

reassessment. The Faceless Scheme,\n2022, though framed under section 151A, consciously omits proceedings\nrelating to inquiry and order under section 148A from its scope.\nConsequently, such proceedings continue to vest with the jurisdictional\nAssessing Officer. Since the notice under section 148 is a direct and\nconsequential outcome of the order passed under section 148A(d), it\nnecessarily follows that

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

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, 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

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

JAGAN MOHAN RAO VALLURU,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

U/S 143(3) r.w.s. 147 of the IT Act,\nby the Deputy Commissioner of Income Tax, Circle-2, Vijayawada, dt\n28.12.2016, is erroneous, bad in law, and liable to be quashed.\n2.\nThat the Learned CIT(A) erred in passing an ex-parte order without\ngranting sufficient and proper opportunity of being heard to the appellant,\nthereby violating the principles

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. VIZAG RE-BARS PRIVATE LIMITED, VISAKHAPATNAM

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.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

143(3) dated 27.12.2019. 4. The Assessee has declared a long term capital gain of Rs. 2,98,48,472/- u/s 10(38) of the Act by selling the entire holdings allotted to the assessee Page. No 3 I.T.A.No.428/VIZ/2024 C.O. No. 16/VIZ/2024 M/s. Vizag Re-Bars Private Limited., pursuant to merger of the GSAL India Limited with Steel Exchange

MARISETTI DHANA TATAJI,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

143(2) of the Act is barred by\nlimitation and therefore is liable to be quashed as invalid and the\nconsequent assessment proceedings are liable to be quashed as void ab\ninitio.\"\nPage. No 4\n9. We admit the legal grounds raised by the assessee as additional grounds\nsince it assails the validity of the assessment order and goes

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

143 or Section 148 or sub- section (1) of Section 153A or sub-section (2) of Section 153C. To sum up, the obligation cast upon an assessee to call in question the jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where he objects to the assumption of jurisdiction

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:

143 or Section 148 or sub- section (1) of Section 153A or sub-section (2) of Section 153C. To sum up, the obligation cast upon an assessee to call in question the jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where he objects to the assumption of jurisdiction

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 148 are fulfilled, the Ld. AO is free to initiate proceedings U/s. 147 of the Act and failure to take steps U/s. 143(3) will not render the Ld. 20 AO powerless to initiate reassessment