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 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 the 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 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 the 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 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 the assessment only

HERMON EDUCATIONAL SOCIETY,VISAKHAPATNAM vs. INCOME TAX OFFICER (EXEMPTION WARD), VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed

Bench: Shri G. Manjunatha & Shri K. Narasimha Chary

Section 68 does not need any introduction. To summarise, it taxes any credit appearing in the books of an assessee, where the assessee is not able to or not satisfactorily able to explain the nature and source of 10 ITA.No.347/VIZ./2024 such credit. It is a deeming fiction, which taxes a credit as income on unsatisfactory explanation about

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

Bench: Shri Ravish Sood, Hon'Bleआयकर अपीलसं./I.T.A.No.428/Viz/2025 (निर्धारण वर्ष/ Assessment Year:2017-18) Srilakshmi Devireddy Vs. Income Tax Officer, Ward-3(5) D.No. 9-58, Loyabata Road Nunna, Vijayawada – 521212 Andhra Pradesh [Pan: Bjupd8440D] Vijayawada करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By Shri C. Subrahmanyam, Ca Shri D. Hema Bhupal, Sr.Dr सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing 16.02.2026 घोषणा की तारीख/Date Of Pronouncement 19.02.2026 Per Ravish Sood, Jm: आदेश /Order The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 12.11.2024, 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 03.12.2019 For The Assessment Year 2017-18. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal:

161 days involved in filing the present appeal by the assessee before the Tribunal. 10. Coming to the merits of the case, I find that as the assessee had failed to come forth with any explanation regarding the source of the cash deposits of Rs. 11,00,000/- made in her bank account, therefore, the AO had held the same

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

section 68 of the Act. In response the assessee, in addition to detailed submissions has also submitted the confirmation letters from the respective creditors. Not satisfied / convinced with the submissions of the assessee, the Ld. AO made addition of Rs. 2 Crs treated the same as unexplained cash credit u/s. 68 of the Act and also disallowed

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , VISAKHAPATNAM vs. ANUMOLU TIRUPATI RAYUDU(HUF),, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

section 68 of the Act. In response the assessee, in addition to detailed submissions has also submitted the confirmation letters from the respective creditors. Not satisfied / convinced with the submissions of the assessee, the Ld. AO made addition of Rs. 2 Crs treated the same as unexplained cash credit u/s. 68 of the Act and also disallowed

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ATR WAREHOUSING PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

section 68 of the Act. In response the assessee, in addition to detailed submissions has also submitted the confirmation letters from the respective creditors. Not satisfied / convinced with the submissions of the assessee, the Ld. AO made addition of Rs. 2 Crs treated the same as unexplained cash credit u/s. 68 of the Act and also disallowed

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, VISAKHAPATNAM vs. HIRAPANNA JEWELLERS, , VISAKHAPATNAM

In the result, appeal of the revenue as well as the cross objection of the assessee are dismissed

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकर अपील सं./I.T.A.No.253/Viz/2020 (निर्धारण वर्ा/Assessment Year:2017-18) Asst.Commissioner Of Vs. M/S Hirapanna Jewellers Income Tax, D.No.48-19-5, Opp:Apsrtc Central Circle-1 Commercial Complex, Visakhapatnam Dwaraka Nagar Visakhapatnam [Pan : Aaifh2606M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Cross Objection No.02/Viz/2021 (Arising Out Of I.T.A. No.253/Viz/2020) (निर्धारण वर्ा/Assessment Year:2017-18) M/S Hirapanna Jewellers Vs. Asst.Commissioner Of D.No.48-19-5, Opp:Apsrtc Income Tax, Commercial Complex, Dwaraka Nagar Central Circle-1 Visakhapatnam Visakhapatnam [Pan : Aaifh2606M]

1 (SC), CIT Vs. P.Mohanakala, 161 Taxman 169 (SC), CIT Vs. Devi Prasad Vishwanath Prasad, 72 ITR 194 SC,, the decision of Hon’ble High Court of Bombay & Goa in CIT Karnataka (Central), Bangalore Vs. Sadiq Sheikh, Tax Appeal No.18 of 9 I.T.A. No.253/Viz/2020 and CO No.02/Viz/2021, A.Y.2017-18 M/s Hirapanna Jewellers, Visakhapatnam 2014, the decision of High Court of Kerala

ARIHANT CONSTRUCTIONS, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1),, VISAKHAPATNAM

In the result, appeals of the assessee for the A

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.321-325/Viz/2019 (ननधधारण वर्ा/Assessment Year : 2011-12 To 2015-16) M/S Arihant Constructions Vs. Asst.Commissioner Of Income Tax M/S B.V.Rao & Co Llp Circle-4(1) Chartered Accountants Visakhapatnam Ff-1, Satya Lakshmi Vinayaka Towers, Madhuranagar Visakhapatnam [Pan : Aarfa0600P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri B.V.Rao, Ar प्रत्यधथी की ओर से / Respondent By : Shri D.V.Subba Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 05.08.2019 घोर्णध की तधरीख/Date Of Pronouncement : 23 .08.2019

68,623 3. Aggrieved by the order of the AO the assessee went on appeal before the CIT(A) and challenged the validity of issue of notice u/s 147 stating that the AO had initiated proceedings u/s 147 due to change of opinion, thus argued that reopening of assessment is invalid, erroneous and contradictory to the facts. The Ld.CIT

ARIHANT CONSTRUCTIONS, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1),, VISAKHAPATNAM

In the result, appeals of the assessee for the A

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.321-325/Viz/2019 (ननधधारण वर्ा/Assessment Year : 2011-12 To 2015-16) M/S Arihant Constructions Vs. Asst.Commissioner Of Income Tax M/S B.V.Rao & Co Llp Circle-4(1) Chartered Accountants Visakhapatnam Ff-1, Satya Lakshmi Vinayaka Towers, Madhuranagar Visakhapatnam [Pan : Aarfa0600P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri B.V.Rao, Ar प्रत्यधथी की ओर से / Respondent By : Shri D.V.Subba Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 05.08.2019 घोर्णध की तधरीख/Date Of Pronouncement : 23 .08.2019

68,623 3. Aggrieved by the order of the AO the assessee went on appeal before the CIT(A) and challenged the validity of issue of notice u/s 147 stating that the AO had initiated proceedings u/s 147 due to change of opinion, thus argued that reopening of assessment is invalid, erroneous and contradictory to the facts. The Ld.CIT

ARIHANT CONSTRUCTIONS, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), , VISAKHAPATNAM

In the result, appeals of the assessee for the A

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.321-325/Viz/2019 (ननधधारण वर्ा/Assessment Year : 2011-12 To 2015-16) M/S Arihant Constructions Vs. Asst.Commissioner Of Income Tax M/S B.V.Rao & Co Llp Circle-4(1) Chartered Accountants Visakhapatnam Ff-1, Satya Lakshmi Vinayaka Towers, Madhuranagar Visakhapatnam [Pan : Aarfa0600P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri B.V.Rao, Ar प्रत्यधथी की ओर से / Respondent By : Shri D.V.Subba Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 05.08.2019 घोर्णध की तधरीख/Date Of Pronouncement : 23 .08.2019

68,623 3. Aggrieved by the order of the AO the assessee went on appeal before the CIT(A) and challenged the validity of issue of notice u/s 147 stating that the AO had initiated proceedings u/s 147 due to change of opinion, thus argued that reopening of assessment is invalid, erroneous and contradictory to the facts. The Ld.CIT

ARIHANT CONSTRUCTIONS, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), , VISAKHAPATNAM

In the result, appeals of the assessee for the A

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.321-325/Viz/2019 (ननधधारण वर्ा/Assessment Year : 2011-12 To 2015-16) M/S Arihant Constructions Vs. Asst.Commissioner Of Income Tax M/S B.V.Rao & Co Llp Circle-4(1) Chartered Accountants Visakhapatnam Ff-1, Satya Lakshmi Vinayaka Towers, Madhuranagar Visakhapatnam [Pan : Aarfa0600P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri B.V.Rao, Ar प्रत्यधथी की ओर से / Respondent By : Shri D.V.Subba Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 05.08.2019 घोर्णध की तधरीख/Date Of Pronouncement : 23 .08.2019

68,623 3. Aggrieved by the order of the AO the assessee went on appeal before the CIT(A) and challenged the validity of issue of notice u/s 147 stating that the AO had initiated proceedings u/s 147 due to change of opinion, thus argued that reopening of assessment is invalid, erroneous and contradictory to the facts. The Ld.CIT

KOTU ANASUYA (LATE),VISAKHAPATNAM vs. DCIT, VISAKHAPATNAM

In the result, appeals filed by the assessees in ITA Nos

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

68,023/- and interest on bank loans for Rs. 96,48,764/- (aggregating to Rs. 1,73,16,783/-) which resulted in loss of Rs.1,71,90,586/-and the same was claimed for set off against the income from other sources, business and capital gains under section 71 of the Act, which the Assessing Officer disputed for disallowance

KOTU SARAT KUMAR,VISAKHAPATNAM vs. DY.CIT., VISAKHAPATNAM

In the result, appeals filed by the assessees in ITA Nos

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

68,023/- and interest on bank loans for Rs. 96,48,764/- (aggregating to Rs. 1,73,16,783/-) which resulted in loss of Rs.1,71,90,586/-and the same was claimed for set off against the income from other sources, business and capital gains under section 71 of the Act, which the Assessing Officer disputed for disallowance

DY CIT, VISAKHAPATNAM vs. KOTU SARATH KUMAR`, VISAKHAPATNAM

In the result, appeals filed by the assessees in ITA Nos

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

68,023/- and interest on bank loans for Rs. 96,48,764/- (aggregating to Rs. 1,73,16,783/-) which resulted in loss of Rs.1,71,90,586/-and the same was claimed for set off against the income from other sources, business and capital gains under section 71 of the Act, which the Assessing Officer disputed for disallowance

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM vs. ANUMOLU AVNASH, VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

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

section 68 of the Act. In response the assessee, in addition to detailed submissions has also submitted the confirmation letters from the respective creditors. Not satisfied / convinced with the submissions of the assessee, the Ld. AO made addition of Rs. 1,64,00,000/- treated the same as unexplained cash credit u/s. 68

R.SURYA NARAYNA,,VISAKHAPATNAM vs. THE ITO , WARD - 5(2),, VISAKHAPATNAM

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

68,785/-. In the assessment proceedings, the assessing officer made the addition of Rs.1,04,29,785/- relating to the sale of property. During the previous year relevant to the assessment year, the assessee has sold the property consisting of land and buildings in plot No.162/B, 161 & 161/A situated at APIIC Pedagantyada in survey No.156 for a consideration of Rs.1