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

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

Bench: Us:

reassessment by the successor A.O. based on a “change of opinion” as against the view taken by his predecessor while framing the assessment vide his order passed u/s 143(3) of the Act, dated 20.04.2009, was not sustainable in the eye of law and was liable to be vacated for want of valid assumption of jurisdiction; and (ii). that

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

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

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

In the result, the appeal filed by the assessee society is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.456/Viz/2025 (िनधा"रण वष"/Assessment Year:2019-20) No.368 Kolakaluru Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-1, Credit Society Limited, Tenali. Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Society 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 Under Section 147 R.W Section 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated

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

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

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

SATYANARAYANA KODURU,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-1, GUDIWADA

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.491/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Satyanarayana Koduru, Vs. Income Tax Officer, Krishna District. Ward-1, Pan:Altpk1048C Gudiwada. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

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

VIKRAM BRAHMENDRA SATYAJIT MULPURI,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-3(1), VIJAYAWADA

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.534/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Vikram Brahmendra Satyajit Vs. Income Tax Officer, Mulpuri, Ward-3(1), Krishna District. Vijayawada. Pan: Aonpm1893G (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm:

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 10 Vikram Brahmendra Satyajit Mulpuri vs. ITO jurisdiction of the A.O as per the mandate of sub-section (3) of Section 124 is confined to a case where

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

NIMMANA NARASIMHARAO,ELURU vs. INCOME TAX OFFICER, WARD-2, ELURU

Bench: Us:

147 of the Act, dated 31.12.2019, in the absence of a notice u/s. 143(2) of the Act having been issued by him is sustainable in the eyes of law? 19. Apropos the validity of the assessment framed by the A.O. vide his order passed u/s 144 of the Act, dated 21.12.2019, wherein he despite taking cognizance of the “return

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)

2,83,28,530/-. 8. Aggrieved, the assessee carried the matter in appeal before the CIT(A), who partly allowed the same. 9. Ostensibly, the CIT(A) rejected the assessee’s contention wherein she had assailed the validity of the jurisdiction that was assumed by the AO for initiating proceedings under Section 147 of the Act. On merits, we find

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

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