ASST.COMMISSIONER OF INCOME TAX, VISAKHAPATNAM vs. THE KANAKA MAHALAKSHMI CO OPERATIVE BANK LTD, VISAKHAPATNAM

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.584/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) The Kanaka Mahalakshmi Vs. Dcit/Acit, Cooperative Bank Limited, Circle-1(1), Visakhapatnam. Visakhapatnam. Pan: Aacft6489J (Appellant) (Respondent) आ.अपी.सं /Ita No.572/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Acit, Vs. The Kanaka Mahalakshmi Cooperative Bank Limited, Visakhapatnam. Visakhapatnam. Pan: Aacft6489J (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Ms. K. Chudamani, Ca राज" व "ारा/Revenue By: Shri Shahnawaz Ul Rahman, Cit-Dr सुनवाई की तारीख/Date Of 26/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Captioned Cross-Appeals Filed By The Assessee Firm/Revenue Are Directed Against The Order Passed By The Commissioner Of Income

220/-. 4. Thereafter, the AO vide his order under section 147 r.w.s 144B of the Act, dated 24/05/2023 determined the income of the assessee at Rs. 27,63,80,380/- after making certain additions, viz., (i) addition under section 68 of the Act on account of unexplained Demand Drafts issued by the assessee society: Rs.19

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, 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:

2), Mumbai, called upon the assessee company to put forth an explanation as to why the impugned loan of Rs. 1 crore received from M/s Aneri Fincap Vedumutha Electricals India Private Limited. Limited (supra) may not be added to its total income as an unexplained cash credit under Section 68 of the Act. In reply, the assessee company tried

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:

2), Mumbai, called upon the assessee company to put forth an explanation as to why the impugned loan of Rs. 1 crore received from M/s Aneri Fincap Vedumutha Electricals India Private Limited. Limited (supra) may not be added to its total income as an unexplained cash credit under Section 68 of the Act. In reply, the assessee company tried

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:

2), Mumbai, called upon the assessee company to put forth an explanation as to why the impugned loan of Rs. 1 crore received from M/s Aneri Fincap Vedumutha Electricals India Private Limited. Limited (supra) may not be added to its total income as an unexplained cash credit under Section 68 of the Act. In reply, the assessee company tried

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:

2), Mumbai, called upon the assessee company to put forth an explanation as to why the impugned loan of Rs. 1 crore received from M/s Aneri Fincap Vedumutha Electricals India Private Limited. Limited (supra) may not be added to its total income as an unexplained cash credit under Section 68 of the Act. In reply, the assessee company tried

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:

2), Mumbai, called upon the assessee company to put forth an explanation as to why the impugned loan of Rs. 1 crore received from M/s Aneri Fincap Vedumutha Electricals India Private Limited. Limited (supra) may not be added to its total income as an unexplained cash credit under Section 68 of the Act. In reply, the assessee company tried

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, GUTNUR vs. ARUNACHALAM MANICKVEL,, GUTNUR

In the result, appeal of the revenue for the A

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhआयकर अपीलसं./I.T.A.No.202/Viz/2020 To 207/Viz/2020 (ननधधारण वर्ा/Assessment Year:2011-12 To 2016-17) Dy.Commissioner Of Vs. Sri Arunachalam Manickavel Income Tax Prop : M/S Bharathi Soap Works Central Circle-1 11/25, Amaravathi Road Guntur Gorantla, Guntur [Pan :Acfpa3107K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit Dr प्रत्यधथी की ओर से / Respondent By : Shri M.V.Prasad, Ar. सुनवधई की तधरीख / Date Of Hearing : 25.11.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Bench :

220 2011-12 12 192 1,78,45,920 2012-13 13 208 1,93,33,080 2013-14 14 224 2,08,37,376 2014-15 11 176 1,65,60,720 Total 9,46,26,216 3.2. The assessee was confronted with the above information gathered during the course of survey at the business premises of M/s Mahaveer

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , GUNTUR vs. ARUNACHALAM MANICKVEL, , GUTNUR

In the result, appeal of the revenue for the A

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhआयकर अपीलसं./I.T.A.No.202/Viz/2020 To 207/Viz/2020 (ननधधारण वर्ा/Assessment Year:2011-12 To 2016-17) Dy.Commissioner Of Vs. Sri Arunachalam Manickavel Income Tax Prop : M/S Bharathi Soap Works Central Circle-1 11/25, Amaravathi Road Guntur Gorantla, Guntur [Pan :Acfpa3107K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit Dr प्रत्यधथी की ओर से / Respondent By : Shri M.V.Prasad, Ar. सुनवधई की तधरीख / Date Of Hearing : 25.11.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Bench :

220 2011-12 12 192 1,78,45,920 2012-13 13 208 1,93,33,080 2013-14 14 224 2,08,37,376 2014-15 11 176 1,65,60,720 Total 9,46,26,216 3.2. The assessee was confronted with the above information gathered during the course of survey at the business premises of M/s Mahaveer

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, GUTNUR vs. ARUNACHALAM MANICKVEL,, GUTNUR

In the result, appeal of the revenue for the A

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhआयकर अपीलसं./I.T.A.No.202/Viz/2020 To 207/Viz/2020 (ननधधारण वर्ा/Assessment Year:2011-12 To 2016-17) Dy.Commissioner Of Vs. Sri Arunachalam Manickavel Income Tax Prop : M/S Bharathi Soap Works Central Circle-1 11/25, Amaravathi Road Guntur Gorantla, Guntur [Pan :Acfpa3107K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit Dr प्रत्यधथी की ओर से / Respondent By : Shri M.V.Prasad, Ar. सुनवधई की तधरीख / Date Of Hearing : 25.11.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Bench :

220 2011-12 12 192 1,78,45,920 2012-13 13 208 1,93,33,080 2013-14 14 224 2,08,37,376 2014-15 11 176 1,65,60,720 Total 9,46,26,216 3.2. The assessee was confronted with the above information gathered during the course of survey at the business premises of M/s Mahaveer

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, GUTNUR vs. ARUNACHALAM MANICKVEL,, GUTNUR

In the result, appeal of the revenue for the A

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhआयकर अपीलसं./I.T.A.No.202/Viz/2020 To 207/Viz/2020 (ननधधारण वर्ा/Assessment Year:2011-12 To 2016-17) Dy.Commissioner Of Vs. Sri Arunachalam Manickavel Income Tax Prop : M/S Bharathi Soap Works Central Circle-1 11/25, Amaravathi Road Guntur Gorantla, Guntur [Pan :Acfpa3107K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit Dr प्रत्यधथी की ओर से / Respondent By : Shri M.V.Prasad, Ar. सुनवधई की तधरीख / Date Of Hearing : 25.11.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Bench :

220 2011-12 12 192 1,78,45,920 2012-13 13 208 1,93,33,080 2013-14 14 224 2,08,37,376 2014-15 11 176 1,65,60,720 Total 9,46,26,216 3.2. The assessee was confronted with the above information gathered during the course of survey at the business premises of M/s Mahaveer

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, GUNTUR vs. ARUNACHALAM MANICKVEL,, GUTNUR

In the result, appeal of the revenue for the A

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhआयकर अपीलसं./I.T.A.No.202/Viz/2020 To 207/Viz/2020 (ननधधारण वर्ा/Assessment Year:2011-12 To 2016-17) Dy.Commissioner Of Vs. Sri Arunachalam Manickavel Income Tax Prop : M/S Bharathi Soap Works Central Circle-1 11/25, Amaravathi Road Guntur Gorantla, Guntur [Pan :Acfpa3107K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit Dr प्रत्यधथी की ओर से / Respondent By : Shri M.V.Prasad, Ar. सुनवधई की तधरीख / Date Of Hearing : 25.11.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Bench :

220 2011-12 12 192 1,78,45,920 2012-13 13 208 1,93,33,080 2013-14 14 224 2,08,37,376 2014-15 11 176 1,65,60,720 Total 9,46,26,216 3.2. The assessee was confronted with the above information gathered during the course of survey at the business premises of M/s Mahaveer

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, GUTNUR vs. ARUNACHALAM MANICKVEL,, GUTNUR

In the result, appeal of the revenue for the A

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhआयकर अपीलसं./I.T.A.No.202/Viz/2020 To 207/Viz/2020 (ननधधारण वर्ा/Assessment Year:2011-12 To 2016-17) Dy.Commissioner Of Vs. Sri Arunachalam Manickavel Income Tax Prop : M/S Bharathi Soap Works Central Circle-1 11/25, Amaravathi Road Guntur Gorantla, Guntur [Pan :Acfpa3107K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Cit Dr प्रत्यधथी की ओर से / Respondent By : Shri M.V.Prasad, Ar. सुनवधई की तधरीख / Date Of Hearing : 25.11.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Bench :

220 2011-12 12 192 1,78,45,920 2012-13 13 208 1,93,33,080 2013-14 14 224 2,08,37,376 2014-15 11 176 1,65,60,720 Total 9,46,26,216 3.2. The assessee was confronted with the above information gathered during the course of survey at the business premises of M/s Mahaveer

SINDHURA HOSPITAL,SRIKAKULAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), VISAKHAPATNAM

Bench: Us:

220 2 Other Expenses 61,88,747 3 Sindhura Hospital Sl. No. Particulars Amount (Rs.) 3 Finance Cost 36,64,051 4 Employees Benefit 58,44,295 5 Cost of Material Consumed 68,59,732 Total 3,87,65,045 4. On verification, it was observed by the A.O. that the “Employees Benefit expenses” of Rs.58,44,295/-, inter alia

CH. VENKATA RAMI REDDY,,VIJAYAWADA vs. THE, ITO,, VIJAYAWADA

In the result, appeals filed by the assessee as well as Revenue are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Blech. Venkata Rami Reddy, Vs. Ito, Ward-2(3), D.No. 54-19-22C, Vijayawada. Flat No. 501, Royal Enclave, Jayaprakashnagar, Lic Colony, Vijayawada. Pan No. Ahgpc 7572 A (Appellant) (Respondent) Ito, Ward-2(3), Vs. Ch. Venkata Rami Reddy, Vijayawada. D.No. 54-19-22C, Flat No. 501, Royal Enclave, Jayaprakashnagar, Lic Colony, Vijayawada. Pan No. Ahgpc 7572 A (Appellant) (Respondent)

220 CTR (Raj) 622, it was held that "neither under provisions of section 68 nor on general principle, it can be said that once existence of persons in whose name credits are found in books of assessee is proved, and such persons own such credits with assessee, still Assessee is to further prove source from which creditors could have

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

68 and that in AIR 1962 SC 29. 7.12 In Websters dictionary, steam is defined as energy. Websters Abridged Dictionary defined it as power or energy. Oxford English Dictionary went a step further in defining steam as mechanical or electrical energy or any form Of energy or force available for application to work (as that of gravitation, running, wind, steam

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

68 and that in AIR 1962 SC 29. 7.12 In Websters dictionary, steam is defined as energy. Websters Abridged Dictionary defined it as power or energy. Oxford English Dictionary went a step further in defining steam as mechanical or electrical energy or any form Of energy or force available for application to work (as that of gravitation, running, wind, steam