THE ACIT, CIRCLE - 1,, RAJAHMUNDRY vs. THE ANDHRA PRADESH PAPER MILLS LTD.,, HYDERABAD

In the result, appeals filed by the Revenue are partly allowed and the cross objections filed by the assessee are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

forward losses and depreciation of eligible business even though they have been allowed to be set off against other income in the earlier years. In view of the specific provisions of section 801A(5), as laid down by the special bench of ITAT Ahmedabad in the case of Gold Minds Shares and Financed by the limited

THE ACIT, CIRCLE - 1,, RAJAHMUNDRY vs. THE ANDHRA PRADESH PAPER MILLS LTD.,, HYDERABAD

In the result, appeals filed by the Revenue are partly allowed and the cross objections filed by the assessee are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

forward losses and depreciation of eligible business even though they have been allowed to be set off against other income in the earlier years. In view of the specific provisions of section 801A(5), as laid down by the special bench of ITAT Ahmedabad in the case of Gold Minds Shares and Financed by the limited

RANAR AGROCHEM LIMITED,PARAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

carried forward against the income assessed to tax This additional ground raised by the appellant is not in agreement with the provisions of Section 68 r.w.s 1158BE of the Act. The plain reading of the Section 115BBE(2) denies any set off of any loss

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), , VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED,, VISAKHAPATNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

68 of the Act is not fulfilled addition made by the Assessing Officer be upheld. 27. Per contra, Ld.AR relied on the order of the Ld. CIT(A). 28. We have heard both the sides and perused the material available on record. Admittedly, Ld. CIT(A) has deleted the amount of Rs. 20,82,145/- Page No. 14 I.T.A.Nos

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED, VISAKHAPTNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

68 of the Act is not fulfilled addition made by the Assessing Officer be upheld. 27. Per contra, Ld.AR relied on the order of the Ld. CIT(A). 28. We have heard both the sides and perused the material available on record. Admittedly, Ld. CIT(A) has deleted the amount of Rs. 20,82,145/- Page No. 14 I.T.A.Nos

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. ALFA ELECTRONIC SERVICES(INDIA) PRIVATE LIMITED, VISAKHAPTNAM

In the result, appeal filed by the revenue is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 50, 51 & 53/Viz/2021 (निर्धारण वर्ा/ Assessment Years: 2013-14, 2014-15 & 2015-16) Acit – Circle – 1(1) V. M/S. Alfa Electronic Services (India) Prathyakshakar Bhavan, Sector – 8 Private Limited Mvp Double Road, 49-22-5, Sri Sai Mansions Visakhapatnam – 530017 Lalitha Nagar, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan: Aahca3583E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

68 of the Act is not fulfilled addition made by the Assessing Officer be upheld. 27. Per contra, Ld.AR relied on the order of the Ld. CIT(A). 28. We have heard both the sides and perused the material available on record. Admittedly, Ld. CIT(A) has deleted the amount of Rs. 20,82,145/- Page No. 14 I.T.A.Nos

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISAKHAPATNAM vs. POOSARLA SATYAVATHI, VIZIANAGARAM

In the result, appeal of the revenue is dismissed in limine and Cross objection filed is assessee is dismissed as infructuous

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

carry forward in the assessment. Page No. 4 I.T.A. No. 227/VIZ/2020 I.T.A. No. 117/VIZ/2021& C.O. No. 13/VIZ/2023 M/s. Linton Projects Private Limited& Smt. Poosarla Satyavathi 6. The appellant may be permitted to submit the further information at the time of hearing of the case. 7. The order of the CIT (Appeals -1) is not justified in confirming the order

LINTON PROJECTS PRIVATE LIMITED,VIZIANAGARAM vs. THE INCOME TAX OFFICER, WARD-1, , VIZIANAGARAM

In the result, appeal of the revenue is dismissed in limine and Cross objection filed is assessee is dismissed as infructuous

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

carry forward in the assessment. Page No. 4 I.T.A. No. 227/VIZ/2020 I.T.A. No. 117/VIZ/2021& C.O. No. 13/VIZ/2023 M/s. Linton Projects Private Limited& Smt. Poosarla Satyavathi 6. The appellant may be permitted to submit the further information at the time of hearing of the case. 7. The order of the CIT (Appeals -1) is not justified in confirming the order

GANESH KUMAR PAIDI,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-2(4), VIJAYAWADA

Appeal is allowed in terms of our aforesaid observations

Bench: Us:

losses and closed the business. The assessing Officer without considering the aforesaid factors has completed the assessment by making an addition of Rs. 73,95,320/- Along with the written submission, the assessee also submitted copy of bills issued by the traders as additional evidence during the appeal proceedings. To verify the claim of the assessee, a remand report

SIONC PHARMACEUTICALS PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM

In the result, appeal of the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.40/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2019-20) Sionc Pharmaceuticals Private Ltd. Vs. Deputy Commissioner Of D.No.43-11-56, Subbalakshminagar Income Railway New Colony Circle-3(1) Visakhapatnam Visakhapatnam [Pan : Aalcs7973C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

68[or increase in income] indicated in the audit report but not taken into account in computing the total income in the return; (v) disallowance of deduction claimed under 69[section 10AA or under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes", if] the return is furnished beyond

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:

carried the matter in appeal before us. 65. We have heard the Ld. Departmental Representative (D.R), perused the orders of the lower authorities and the material available on record. Vedumutha Electricals India Private Limited. 66. Admittedly, it is a matter of fact borne from the record that the assessee company had during the subject year claimed to have raised

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:

carried the matter in appeal before us. 65. We have heard the Ld. Departmental Representative (D.R), perused the orders of the lower authorities and the material available on record. Vedumutha Electricals India Private Limited. 66. Admittedly, it is a matter of fact borne from the record that the assessee company had during the subject year claimed to have raised

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:

carried the matter in appeal before us. 65. We have heard the Ld. Departmental Representative (D.R), perused the orders of the lower authorities and the material available on record. Vedumutha Electricals India Private Limited. 66. Admittedly, it is a matter of fact borne from the record that the assessee company had during the subject year claimed to have raised

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:

carried the matter in appeal before us. 65. We have heard the Ld. Departmental Representative (D.R), perused the orders of the lower authorities and the material available on record. Vedumutha Electricals India Private Limited. 66. Admittedly, it is a matter of fact borne from the record that the assessee company had during the subject year claimed to have raised

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:

carried the matter in appeal before us. 65. We have heard the Ld. Departmental Representative (D.R), perused the orders of the lower authorities and the material available on record. Vedumutha Electricals India Private Limited. 66. Admittedly, it is a matter of fact borne from the record that the assessee company had during the subject year claimed to have raised

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

68 of the IT Act. 5. Without prejudice to the above ground, the Assessing Officer and Ld. CIT(A) have not considered the fact that the reopening of the assessment is without recording reasons. 6. The Ld. CIT(A) would have observed that the reopening of the assessment is bad in law as the Assessing Officer reopened assessment only

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

68 of the IT Act. 5. Without prejudice to the above ground, the Assessing Officer and Ld. CIT(A) have not considered the fact that the reopening of the assessment is without recording reasons. 6. The Ld. CIT(A) would have observed that the reopening of the assessment is bad in law as the Assessing Officer reopened assessment only

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

68 of the IT Act. 5. Without prejudice to the above ground, the Assessing Officer and Ld. CIT(A) have not considered the fact that the reopening of the assessment is without recording reasons. 6. The Ld. CIT(A) would have observed that the reopening of the assessment is bad in law as the Assessing Officer reopened assessment only