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

153A of the Act was issued on 15.09.2018. In response, assessee filed her Return of Income electronically for the A.Y.2014-15 on 17.10.2018 declaring Total Income at Rs. 2,56,940/-. Subsequently, statutory notices under section 143(2) and 142(1) of the Act were issued and served on the assessee. In response to the above notices, Authoritized Representative

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

153A of the Act was issued on 15.09.2018. In response, assessee filed her Return of Income electronically for the A.Y.2014-15 on 17.10.2018 declaring Total Income at Rs. 2,56,940/-. Subsequently, statutory notices under section 143(2) and 142(1) of the Act were issued and served on the assessee. In response to the above notices, Authoritized Representative

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, VISAKHAPATNAM vs. SAI KANAKA MAHALAKSHMI FINANCE PRIVATE LIMITED., KOLKATA

In the result, appeal of the Revenue is dismissed and the petition filed by the assessee under Rule 27 is allowed as indicated herein above

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

68 of the Act towards unexplained share capital. 2. Being aggrieved, the petitioner filed an appeal before the Ld. CIT(A)-3, Visakhapatnam vide ITA No. 10551/2019-20. In this appeal, the petitioner contested the assessment order not only on merits but also on various legal objections. The following legal issues were raised before the Ld. CIT(A). a. The addition

INCOME TAX OFFICER, WARD-2(5), VISAKHAPATNAM vs. DUVVURU REKHA REDDY, KURMANNAPALEM

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.450/Viz/2024 (निर्धारण वर्ा/ Assessment Year:2017-18) Vs. Income Tax Officer –Ward– 2(5) Duvvuru Rekha Reddy 2Nd Floor, Infinity Towers Flat No. 402, Vizag Profile Towers Sankaramatam Road Kurmannapalem Visakhapatnam - 530016 Visakhapatnam -530046 Andhra Pradesh [Pan:Afdpr3780C] सी.ओ सं. / C.O. No. 17/Viz/2024 [आयकरअपीलसं.से उत्पन्न/I.T.A.No.450/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18)] Vs. Income Tax Officer –Ward– 2(5) Duvvuru Rekha Reddy 2Nd Floor, Infinity Towers Flat No. 402, Vizag Profile Towers Sankaramatam Road Kurmannapalem Visakhapatnam - 530016 Visakhapatnam - 530046 Andhra Pradesh [Pan:Afdpr3780C]

68 of the Act towards unexplained cash credits. Page. No 4 I.T.A.No.450/VIZ/2024 C.O. No. 17/VIZ/2024 Duvvuru Rekha Reddy 2. The learned Commissioner of Income-Tax (Appeals) is justified in deleting the addition of Rs.11,62,080 made by the assessing officer u/s 69C of the Act towards alleged unexplained payment of commission. 3. The learned Commissioner of Income

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

153A assessments. 13. Further, with respect to Ground No.4(d) it was contended by the Ld. AR that when there was no seizure in the Panchnama dated 6/8/2020, such Panchnama without any seizure cannot be considered for the purpose of computing the period of limitation. The Ld AR placed reliance on the following case laws: Pr. CIT vs. PPC Business

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

153A.\n30. The Ld. CIT(A) ought to have considered the decision of Hon'ble\nSupreme Court in the case Of Bannalal Jat Constructions P Ltd Vs ACIT\n(2019) 106 Taxmann.com 128(SC)/264 Taxmann .S(SC), wherein it was\nheld that \"where High Court upheld the addition made by authorities below\nPage No. 12\nITA

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

153A.\n15. The Ld. CIT(A) ought to have considered the decision of Hon'ble\nSupremeCourt in the case of Bannalal Jat Constructions P Ltd Vs ACIT (2019)\n106Taxmann.com 128(SC)/264 Taxmann (SC), wherein it was held that"where\nHigh Court upheld the addition made by authorities below relying upon\nstatement made in course of search proceedings by Director

GVA INDUSTRIES PRIVATE LIMITED,CHHATTISGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

153A.\n15. The Ld. CIT(A) ought to have considered the decision of Hon'ble\nSupremeCourt in the case of Bannalal Jat Constructions P Ltd Vs ACIT (2019)\n106Taxmann.com 128(SC)/264 Taxmann (SC), wherein it was held that"where\nHigh Court upheld the addition made by authorities below relying upon\nstatement made in course of search proceedings by Director

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

153A.\n15. The Ld. CIT(A) ought to have considered the decision of Hon'ble\nSupremeCourt in the case of Bannalal Jat Constructions P Ltd Vs ACIT (2019)\n106Taxmann.com 128(SC)/264 Taxmann (SC), wherein it was held that"where\nHigh Court upheld the addition made by authorities below relying upon\nstatement made in course of search proceedings by Director

GVA INDUSTRIES PRIVATE LIMITED,CHHATTISGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

153A.\n15. The Ld. CIT(A) ought to have considered the decision of Hon'ble\nSupremeCourt in the case of Bannalal Jat Constructions P Ltd Vs ACIT (2019)\n106Taxmann.com 128(SC)/264 Taxmann (SC), wherein it was held that"where\nHigh Court upheld the addition made by authorities below relying upon\nstatement made in course of search proceedings by Director