ARAVIND REDDY DEVAGIRI,GUNTUR vs. INCOME TAX OFFICE, WARD-2(2), GUNTUR

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.267/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Aravind Reddy Devagiri V. Income Tax Officer – Ward 2(2) 14-19-35, 1St Lane Vijayapuri Guntur Andhra Pradesh Jkc College Road, Guntur 522006 Andhra Pradesh [Pan: Auepd7820R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 68 r.w.s. 115BBE of the Act of Rs.11,40,665/-. ii. Addition on account of introduction of capital

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.

40,000/-; (iii) addition of the unreconciled interest income as reflected in Form No. 26AS vis-à-vis books of account of Rs. 1,35,680/-; and (iv) addition of the unsecured loans as unexplained cash credits under section 68

MANOHARMAL,VIJAYAWADA vs. ITO, WARD-2(1), VIJAYAWADA

Bench: Shri Ravish Sood, Hon’Ble

40,000/-under section 68 of the I.T. Act of gift received from his daughter Neelam as the source

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

40. Ground No.7 relating to gratuity premium payment, is a similar ground raised in ITA No. 176/VIZ/2013 as ground No.5. In view of our decision in the above referred to appeal, this ground of appeal raised by the assessee is allowed for statistical purposes. 41. Ground No.8 relating to disallowance of contingency fund. The Assessing Officer has noted that

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

40. Ground No.7 relating to gratuity premium payment, is a similar ground raised in ITA No. 176/VIZ/2013 as ground No.5. In view of our decision in the above referred to appeal, this ground of appeal raised by the assessee is allowed for statistical purposes. 41. Ground No.8 relating to disallowance of contingency fund. The Assessing Officer has noted that

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

40. Ground No.7 relating to gratuity premium payment, is a similar ground raised in ITA No. 176/VIZ/2013 as ground No.5. In view of our decision in the above referred to appeal, this ground of appeal raised by the assessee is allowed for statistical purposes. 41. Ground No.8 relating to disallowance of contingency fund. The Assessing Officer has noted that

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

40. Ground No.7 relating to gratuity premium payment, is a similar ground raised in ITA No. 176/VIZ/2013 as ground No.5. In view of our decision in the above referred to appeal, this ground of appeal raised by the assessee is allowed for statistical purposes. 41. Ground No.8 relating to disallowance of contingency fund. The Assessing Officer has noted that

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 68 of the Act. 31. On appeal before the ld. CIT(A), ld. counsel has reiterated the submissions which he was made before the Assessing Officer but, no evidence is filed. Therefore, ld. CIT(A) confirmed the order of the Assessing Officer. Even before us also, no evidence with reference to the advance received from Sri W. Raju

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 68 of the Act. 31. On appeal before the ld. CIT(A), ld. counsel has reiterated the submissions which he was made before the Assessing Officer but, no evidence is filed. Therefore, ld. CIT(A) confirmed the order of the Assessing Officer. Even before us also, no evidence with reference to the advance received from Sri W. Raju

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 68 of the Act. 31. On appeal before the ld. CIT(A), ld. counsel has reiterated the submissions which he was made before the Assessing Officer but, no evidence is filed. Therefore, ld. CIT(A) confirmed the order of the Assessing Officer. Even before us also, no evidence with reference to the advance received from Sri W. Raju

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 68 of the Act. 31. On appeal before the ld. CIT(A), ld. counsel has reiterated the submissions which he was made before the Assessing Officer but, no evidence is filed. Therefore, ld. CIT(A) confirmed the order of the Assessing Officer. Even before us also, no evidence with reference to the advance received from Sri W. Raju

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

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 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)

68 of the Act is not fulfilled addition made by the Assessing Officer be upheld. 27. Per contra, Ld.AR relied on the order of the Ld. CIT(A). 28. We have heard both the sides and perused the material available on record. Admittedly, Ld. CIT(A) has deleted the amount of Rs. 20,82,145/- Page No. 14 I.T.A.Nos

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)

68 of the Act is not fulfilled addition made by the Assessing Officer be upheld. 27. Per contra, Ld.AR relied on the order of the Ld. CIT(A). 28. We have heard both the sides and perused the material available on record. Admittedly, Ld. CIT(A) has deleted the amount of Rs. 20,82,145/- Page No. 14 I.T.A.Nos

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)

68 of the Act is not fulfilled addition made by the Assessing Officer be upheld. 27. Per contra, Ld.AR relied on the order of the Ld. CIT(A). 28. We have heard both the sides and perused the material available on record. Admittedly, Ld. CIT(A) has deleted the amount of Rs. 20,82,145/- Page No. 14 I.T.A.Nos

KANCHAN LALWANI,VIZIANAGARAM vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 1, VISAKHAPATNAM

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A. No.265/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2021-22) Kanchan Lalwani V. Pr.Cit -1 22-1-22, Phho Baugh Road Aayakar Bhavan, Daba Gardens Ambati Satram Junction Visakhapatnam – 530020 Khadarnagar, Vizianagaram – 535002 Andhra Pradesh Andhra Pradesh [Pan: Abepl4375Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 68 of the Act towards unexplained cash credit and Rs.45,40,750/- towards disallowance under section 56(2)(x) of the Act. 3. Subsequently

KANCHAN LALWANI,VIZIANAGARAM vs. INCOME TAX OFFICER, WARD-1, VIZIANAGARAM

In the result, the appeal filed by the assessee is allowed

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

68 is illegal, invalid and bad in law; 6. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre erred in not considering that assessee has specifically objected the stamp duty value, therefore confirming addition made U/s. 56(2)(x)(b) * B of Rs. 45,40,70/- without referring matter to DVO on assumption and presumption basis is illegal

SATHI MANGAYAMMA,EAST GODAVARI DIST vs. INCOME TAX OFFICER, WARD-2, KAKINADA

Appeal is allowed in terms of our aforesaid observations

Bench: Us :

40,000/-. Out of the total credits of Rs.2,35,89,500/-, there were cash deposits of Rs.20,00,500/- made by the assessee in her aforesaid bank account during the demonetization period. As the assessee despite sufficient opportunities failed to respond to the notices issued by the A.O., therefore, the latter was constrained to proceed with and frame