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)

10,031/- in respect of VAT Payable under section 43B of the Act. In addition, Assessing Officer also further made an addition of Rs. 1,23,92,145/- towards disallowance of unsecured loans under section 68

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)

10,031/- in respect of VAT Payable under section 43B of the Act. In addition, Assessing Officer also further made an addition of Rs. 1,23,92,145/- towards disallowance of unsecured loans under section 68

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. VENKATRAMA POULTRIES PVT. LTD, GUNTUR

Section 68 and 69C of the Income\nTax Act. The entire purchases shown on the basis of fictitious invoices have\nbeen debited in the trading account Since the transaction of Rs.2,92,93,288/\nrepresented alleged purchases -from bogus suppliers it was not incumbent\non it to restrict the disallowance to only Rs.73,23,322/-" The CIT(A) ought

ASSISTANT COMMISSIONER OF INCOME TAX, GUNTUR vs. DONKALA CHENCHU NARASIMHA RAO, NELLORE

10 11 12 13 14\n15 16 17 18 19 20 21\n22 23 24 25 26 27 26\n19. mahAbuddhir mahAyiryo mahAshaktir mahAdhyuthill\nanirdeshyavapub slarimAn amey AtmA mahAdbri dhRk\nPage. No 6\nI.T.A.No.408/VIZ/2025\nI.T.A.No.460/VIZ/2025\nDonakala Chenchu Narasimha Rao --\n9. The contention of the Ld.AR is that these cash payments was made for\nthe purpose of business

THE ITO,, VISAKHAPATNAM vs. M/S. GOWTHAMI BUILDERS,, VISAKHAPATNAM

In the result, appeals filed by the Revenue are dismissed and the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble & M/S. Gowthami Builders, Vs. Ito, Ward-1(4), D.No. 48-3-6, Srinagar, Visakhapatnam. Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent) & Ito, Ward-1(4), Vs. M/S. Gowthami Builders, Visakhapatnam. D.No. 48-3-6, Srinagar, Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent)

section 142(1) dated 23-01-2014, besides asking the names and complete addreses of the parties from whom the loans were alleged to be raised, the assessee firm was asked to explain the sources and creditworthiness of the lenders and genuineness of the transactions along with verifiable supporting evidences. In response to the same vide its letter submitted

ITO, WARD-1(4), , VISAKHAPATNAM vs. GOWTHAMI BUILDERS,, VISAKHAPATNAM

In the result, appeals filed by the Revenue are dismissed and the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble & M/S. Gowthami Builders, Vs. Ito, Ward-1(4), D.No. 48-3-6, Srinagar, Visakhapatnam. Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent) & Ito, Ward-1(4), Vs. M/S. Gowthami Builders, Visakhapatnam. D.No. 48-3-6, Srinagar, Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent)

section 142(1) dated 23-01-2014, besides asking the names and complete addreses of the parties from whom the loans were alleged to be raised, the assessee firm was asked to explain the sources and creditworthiness of the lenders and genuineness of the transactions along with verifiable supporting evidences. In response to the same vide its letter submitted

M/S. COWTHAMI BUILDERS,,VISAKHAPATNAM vs. THE ITO,, VISAKHAPATNAM

In the result, appeals filed by the Revenue are dismissed and the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble & M/S. Gowthami Builders, Vs. Ito, Ward-1(4), D.No. 48-3-6, Srinagar, Visakhapatnam. Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent) & Ito, Ward-1(4), Vs. M/S. Gowthami Builders, Visakhapatnam. D.No. 48-3-6, Srinagar, Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent)

section 142(1) dated 23-01-2014, besides asking the names and complete addreses of the parties from whom the loans were alleged to be raised, the assessee firm was asked to explain the sources and creditworthiness of the lenders and genuineness of the transactions along with verifiable supporting evidences. In response to the same vide its letter submitted

GOWTHAMI BUILDERS,,VISAKHAPATNAM vs. THE ITO,, VISAKHAPATNAM

In the result, appeals filed by the Revenue are dismissed and the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble & M/S. Gowthami Builders, Vs. Ito, Ward-1(4), D.No. 48-3-6, Srinagar, Visakhapatnam. Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent) & Ito, Ward-1(4), Vs. M/S. Gowthami Builders, Visakhapatnam. D.No. 48-3-6, Srinagar, Visakhapatnam. Pan No. Aaifg 6738 K (Appellant) (Respondent)

section 142(1) dated 23-01-2014, besides asking the names and complete addreses of the parties from whom the loans were alleged to be raised, the assessee firm was asked to explain the sources and creditworthiness of the lenders and genuineness of the transactions along with verifiable supporting evidences. In response to the same vide its letter submitted

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

section 68 of the Act. 20. Per contra, it was the submission of the Ld. DR that the sale prices of the shares of the Sri Bhagwan Builders Private Limited and Shri Bhagwan Niketan Limited are abnormal and the assessee used it as the devise to explain the sources for the investment in the assessee company. He therefore pleaded

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

section 68 of the Act. 20. Per contra, it was the submission of the Ld. DR that the sale prices of the shares of the Sri Bhagwan Builders Private Limited and Shri Bhagwan Niketan Limited are abnormal and the assessee used it as the devise to explain the sources for the investment in the assessee company. He therefore pleaded

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.

10,87,000/- that was received by the assessee company. The AO, observing that the assessee company had substantiated the authenticity of the loan transactions pertaining to the said seven persons, accepted the same. At the same time, the AO observed that the assessee company had failed to produce either complete addresses or confirmation letters from eight parties, from whom

DONKALA CHENCHU NARASIMHA RAO,NELLORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

10 11 12 13 14\n15 16 17 18 19 20 21\n22 23 24 25 26 27 26\n19. mahAbuddhir mahAyiryo mahAshaktir mahAdhyuthill\nanirdeshyavapub slarimAn amey AtmA mahAdbri dhRk\nPage. No 6\nI.T.A.No.408/VIZ/2025\nI.T.A.No.460/VIZ/2025\nDonakala Chenchu Narasimha Rao --\n9.\nThe contention of the Ld.AR is that these cash payments was made for\nthe purpose of business

THE ARYAPURAM CO-OPERATIVE URBAN BANK LTD.,RAJAHMUNDRY vs. THE ACIT,, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

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

23,79,60,181/- by invoking the provisions of section 68 of the Act. The ld. CIT(A) directed the Assessing Officer to examine the details and asked him to submit remand report. The Assessing Officer has submitted the remand report, which is reproduced as under:- (The Aryapuram Co-op. Urban Bank Ltd.) “4. Since the assessee-bank

THE ARYAPURAM CO-OPERATIVE URBAN BANK LTD.,,RAJAHMUNDRY vs. THE ACIT, CIRCLE - 1, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

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

23,79,60,181/- by invoking the provisions of section 68 of the Act. The ld. CIT(A) directed the Assessing Officer to examine the details and asked him to submit remand report. The Assessing Officer has submitted the remand report, which is reproduced as under:- (The Aryapuram Co-op. Urban Bank Ltd.) “4. Since the assessee-bank

ARYAPURAM CO=OP. URBANK LTD.,,RAJAHMUNDRY vs. THE ACIT,, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

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

23,79,60,181/- by invoking the provisions of section 68 of the Act. The ld. CIT(A) directed the Assessing Officer to examine the details and asked him to submit remand report. The Assessing Officer has submitted the remand report, which is reproduced as under:- (The Aryapuram Co-op. Urban Bank Ltd.) “4. Since the assessee-bank

THE ACIT,CIRCLE - 1,, RAJAHMUNDRY vs. M/STHE ARYAPURAM CO-OPRATIVE URBAN BANK LTD.,, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

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

23,79,60,181/- by invoking the provisions of section 68 of the Act. The ld. CIT(A) directed the Assessing Officer to examine the details and asked him to submit remand report. The Assessing Officer has submitted the remand report, which is reproduced as under:- (The Aryapuram Co-op. Urban Bank Ltd.) “4. Since the assessee-bank

DCIT, CENTRAL CIRCLE-1, VISAKHAPATNAM vs. GVA INDUSTRIES PVT. LTD., DHAMTARI

68 and 69C of the Income Tax Act. The entire purchases\nshown on the basis of fictitious invoices have been debited in the trading\naccount since the transaction of Rs. 2,92,93,288/- represented alleged\npurchases from bogus suppliers it was not incumbent on it to restrict the\nPage. No 8\nI.T.A.Nos. 137, 138 & 139/VIZ/2025\nM/s. GVA Industries Private

DCIT, CENTRAL CIRCLE-1, VISAKHAPATNAM vs. GVA INDUSTRIES PVT. LTD., DHAMTARI

68 and 69C of the Income Tax Act. The entire purchases\nshown on the basis of fictitious invoices have been debited in the trading\naccount since the transaction of Rs. 2,92,93,288/- represented alleged\npurchases from bogus suppliers it was not incumbent on it to restrict the\nPage. No 8\nI.T.A.Nos.137, 138 & 139/VIZ/2025\nI.T.A.Nos