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)

26. Ground No. 5 is with respect to deletion of addition of unsecured loans amount of Rs. 1,03,10,000/-. Ld. DR submitted that the assessee has taken unsecured loans from various parties but has failed to prove the identity, genuineness and credit worthiness of the parties. He therefore pleaded that since the three conditions specified under section

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)

26. Ground No. 5 is with respect to deletion of addition of unsecured loans amount of Rs. 1,03,10,000/-. Ld. DR submitted that the assessee has taken unsecured loans from various parties but has failed to prove the identity, genuineness and credit worthiness of the parties. He therefore pleaded that since the three conditions specified under section

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)

26. Ground No. 5 is with respect to deletion of addition of unsecured loans amount of Rs. 1,03,10,000/-. Ld. DR submitted that the assessee has taken unsecured loans from various parties but has failed to prove the identity, genuineness and credit worthiness of the parties. He therefore pleaded that since the three conditions specified under section

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

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\nPage

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 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

10,00,000/- u/s. 68 of the Act as not explained. 22. Even before us, Ld. AR has not furnished any documentary evidences regarding the sources of cash gifts received by the four members of the family for the purpose of investment in the assessee company. Therefore, we are of the considered view that the investment by the four individual

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

10,00,000/- u/s. 68 of the Act as not explained. 22. Even before us, Ld. AR has not furnished any documentary evidences regarding the sources of cash gifts received by the four members of the family for the purpose of investment in the assessee company. Therefore, we are of the considered view that the investment by the four individual

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

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)

68,99,450/- brought into the assessee firm's, in the guise of unsecured loans, as unexplained investment and bring the same to tax. Accordingly vide this office letter dated 07-03-2014 the assessee firm was requested to file its objections for the same along with necessary supporting evidences In response to the same the assessee firm has 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)

68,99,450/- brought into the assessee firm's, in the guise of unsecured loans, as unexplained investment and bring the same to tax. Accordingly vide this office letter dated 07-03-2014 the assessee firm was requested to file its objections for the same along with necessary supporting evidences In response to the same the assessee firm has submitted

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)

68,99,450/- brought into the assessee firm's, in the guise of unsecured loans, as unexplained investment and bring the same to tax. Accordingly vide this office letter dated 07-03-2014 the assessee firm was requested to file its objections for the same along with necessary supporting evidences In response to the same the assessee firm has 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)

68,99,450/- brought into the assessee firm's, in the guise of unsecured loans, as unexplained investment and bring the same to tax. Accordingly vide this office letter dated 07-03-2014 the assessee firm was requested to file its objections for the same along with necessary supporting evidences In response to the same the assessee firm has submitted

ACE URBAN DEVELOPERS PRIVATE LIMITED,HYDERABAD vs. AO, NFAC

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.79, 118 & 284/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2016-17, 2018-19 & 2016-17) Ace Urban Developers Private Limited V. The Asst. Cit- Circle-2(1) Module No. A1, A2,A3 Vijayawada – 520002 Quadrant No. 4, 4Thfloor Andhra Pradesh Cyber Tower, Hitech City Madhapur B.O. Sheikpet, Hyderabad-500081, Telangana [Pan: Aanca4001H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Sk Gupta,Ar राजस्व का प्रतततितित्व / Department Represented By : Dr. Satyasai Rath, Sr.Ar

26,853/-; c. Unsecured loan amounting Rs. 4 Crore treated as unexplained sum under section 68 of the Act; d. Interest thereon of Rs. 3.79,315/-; and e. Share Capital of Rs. 27 Crore treated as unexplained sum under section 68 of the Act. Page No. 2 I.T.A.Nos.79, 118 & 284/VIZ/2024 ACE URBAN DEVELOPERS PRIVATE LIMITED 4. Thereafter

ACE URBAN DEVELOPERS PRIVATE LIMITED,HYDERABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.79, 118 & 284/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2016-17, 2018-19 & 2016-17) Ace Urban Developers Private Limited V. The Asst. Cit- Circle-2(1) Module No. A1, A2,A3 Vijayawada – 520002 Quadrant No. 4, 4Thfloor Andhra Pradesh Cyber Tower, Hitech City Madhapur B.O. Sheikpet, Hyderabad-500081, Telangana [Pan: Aanca4001H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Sk Gupta,Ar राजस्व का प्रतततितित्व / Department Represented By : Dr. Satyasai Rath, Sr.Ar

26,853/-; c. Unsecured loan amounting Rs. 4 Crore treated as unexplained sum under section 68 of the Act; d. Interest thereon of Rs. 3.79,315/-; and e. Share Capital of Rs. 27 Crore treated as unexplained sum under section 68 of the Act. Page No. 2 I.T.A.Nos.79, 118 & 284/VIZ/2024 ACE URBAN DEVELOPERS PRIVATE LIMITED 4. Thereafter

ACE URBAN DEVELOPERS PRIVATE LIMITED,HYDERABAD vs. AO, VIJAYAWADA

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.79, 118 & 284/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2016-17, 2018-19 & 2016-17) Ace Urban Developers Private Limited V. The Asst. Cit- Circle-2(1) Module No. A1, A2,A3 Vijayawada – 520002 Quadrant No. 4, 4Thfloor Andhra Pradesh Cyber Tower, Hitech City Madhapur B.O. Sheikpet, Hyderabad-500081, Telangana [Pan: Aanca4001H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Sk Gupta,Ar राजस्व का प्रतततितित्व / Department Represented By : Dr. Satyasai Rath, Sr.Ar

26,853/-; c. Unsecured loan amounting Rs. 4 Crore treated as unexplained sum under section 68 of the Act; d. Interest thereon of Rs. 3.79,315/-; and e. Share Capital of Rs. 27 Crore treated as unexplained sum under section 68 of the Act. Page No. 2 I.T.A.Nos.79, 118 & 284/VIZ/2024 ACE URBAN DEVELOPERS PRIVATE LIMITED 4. Thereafter

SRILAKSHMI DEVIREDDY,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-3(5), VIJAYAWADA

68, section 69, section 69A, section 69B, section 69C or section 69D was\nenhanced from 30% to 60%, was applicable only to the transactions from 01.4.2017 and\ncould not be applied retrospectively. The Ld.AR submitted that the Tribunal in its\naforesaid orders had specifically observed that the higher rate of tax @60% under\nsection 115BBE

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

26. On the other hand, ld. Departmental Representative strongly supported the orders of the authorities below. 27. We have heard both the parties, perused the material available on record and gone through orders of the authorities below. 28. In this case, ld. CIT(A) gave a categorical finding that the assessee by creating establishment fund, violated section 116C

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

26. On the other hand, ld. Departmental Representative strongly supported the orders of the authorities below. 27. We have heard both the parties, perused the material available on record and gone through orders of the authorities below. 28. In this case, ld. CIT(A) gave a categorical finding that the assessee by creating establishment fund, violated section 116C

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

26. On the other hand, ld. Departmental Representative strongly supported the orders of the authorities below. 27. We have heard both the parties, perused the material available on record and gone through orders of the authorities below. 28. In this case, ld. CIT(A) gave a categorical finding that the assessee by creating establishment fund, violated section 116C