ASHA SANGHAVI,RAJAHMUNDRY vs. INCOME TAX OFFICER, WARD-2, , RAJAHMUNDRY

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.33/Viz/2019 (ननधधारण वर्ा/Assessment Year : 2011-12) Smt.Asha Sanghavi Vs. Income Tax Officer D.No.7-22-12 Ward-2 Nandepu Heights Rajamahendravaram T.Nagar Rajamahendravaram [Pan : Awfps2816R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri D.Manoj Kumar, Dr सुनवधई की तधरीख / Date Of Hearing : 06.11.2019 घोर्णध की तधरीख/Date Of Pronouncement : 15.11.2019 आदेश /O R D E R

50,000 (b) Oriental Bank of Commerce Rs.26,00,000 (c) Federal Bank Rs.37,80,000 (d) Barclays Rs.8,79,000 6.1. The AO asked the assessee to explain the source of monies deposited in the bank accounts and the assessee filed the reply explaining the sources as under : “In this connection, it may be submitted that the sources

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. In this regard, one may profitably refer to the judgment of the Apex Court in case of Kale Khan Mohammad Hanif vs. CIT [1963] 50

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. 115 BBE of the Act of Rs.24,50,000/-. iii. Addition towards investment in two firms

SANTOSH AGRAWAL,CHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRLCE-1, VISAKHAPATNAM

section 68\nof the Act.\n8. Further, it was also observed by the Ld. AO that the assessee and its\nfamily members had invested in M/s. Maa Mahamaya Industries Limited and\nM/s. GVA Industries Pvt. Ltd. Ld. AO found that initially huge share capital\nwas invested by several companies based at Kolkata and Delhi. The shares\nwere allotted

ASSISTANT COMMISSIONER OF INCOME TAX, GUNTUR vs. DONKALA CHENCHU NARASIMHA RAO, NELLORE

50,000/-) and by Hon'ble ITAT\n(Addition of Rs. 89,62,515/-). Further appellant submitted AO cannot\nresort to methodology of telescoping of such amounts in the hands of the\nappellant against the on money payment for purchase of property. The\nnotion of the AO that the theory of telescoping can be applied in the\nappellant's case

ASHOK KUMAR AGRAWAL,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

section 68\nof the Act.\n\n8. Further, it was also observed by the Ld. AO that the assessee and its\nfamily members had invested in M/s. Maa Mahamaya Industries Limited and\nM/s. GVA Industries Pvt. Ltd. Ld. AO found that initially huge share capital\nwas invested by several companies based at Kolkata and Delhi. The shares\nwere allotted

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.

50,000/-; and (ii)j loans from the remaining thirty-three persons: Rs.2,73,47,000/- as unexplained cash credits under section 68

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)

section 68 of the Page No. 10 I.T.A.Nos.50, 51 & 53/VIZ/2021 M/s. Alfa Electronic Services (India) Private Limited Act. Assessing

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)

section 68 of the Page No. 10 I.T.A.Nos.50, 51 & 53/VIZ/2021 M/s. Alfa Electronic Services (India) Private Limited Act. Assessing

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)

section 68 of the Page No. 10 I.T.A.Nos.50, 51 & 53/VIZ/2021 M/s. Alfa Electronic Services (India) Private Limited Act. Assessing

DONKALA CHENCHU NARASIMHA RAO,NELLORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

50,000/-) and by Hon'ble ITAT\n(Addition of Rs. 89,62,515/-). Further appellant submitted AO cannot\nresort to methodology of telescoping of such amounts in the hands of the\nappellant against the on money payment for purchase of property. The\nnotion of the AO that the theory of telescoping can be applied in the\nappellant's case

SRI RAJANI GOLD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.162/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2017-18) Sri Rajani Gold V. Asst. Cit – Circle – 1(1) D.No. 11-49-336B Central Revenue Building Sivalayam Street, I Town Mg Road – 520001 Vijayawada – 520001 Vijayawada, Andhra Pradesh Andhra Pradesh [Pan: Aacfs6675E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

50,271 0.03% 2016-17 150,89,00,721 1,30,404 0.01% 2017-18 79,92,05,016 43,31,082 0.54% 7. Considering the business and turnover of the assessee, Ld.AO estimated the income of the assessee at 1% of the turnover of Rs. 79,92,05,016/- amounting to Rs. 79,92,050/-. 8. The Ld.AO rejected

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

68 of the Act. On this issue, Ld. AR submitted that during the impugned assessment year 34 shareholders have invested in the assessee company by acquiring the equity shares on the face value of Rs 10/- each for a premium of Rs.45/- per share. Ld. AR further submitted that, out of 34 Page No. 5 I.T.A. No. 227/VIZ/2020 I.T.A

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

68 of the Act. On this issue, Ld. AR submitted that during the impugned assessment year 34 shareholders have invested in the assessee company by acquiring the equity shares on the face value of Rs 10/- each for a premium of Rs.45/- per share. Ld. AR further submitted that, out of 34 Page No. 5 I.T.A. No. 227/VIZ/2020 I.T.A

SANDHI RAJA SEKHAR ,BHIMAVARAM vs. INCOME TAX OFFICER, WARD-1, BHIMAVARAM

In the result, appeal filed by the assessee is allowed

Bench: Shrik Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./ I.T.A. 296/Viz/2024 (ननधधारणवर्ा/ Assessment Year : 2013-14) Sandhi Raja Sekhar, Vs. Income Tax Officer, Bhimavaram. Ward-1, Pan: Axrps2387J Bhimavaram. (अपीलधथी/ Appellant) (प्रत्यथी/ Respondent) अपीलधथी की ओर से/ Assessee By : Sri Gvn Hari, Ar प्रत्यधथी की ओर से/ Revenue By : Dr. Aparna Villuri, Sr. Ar

50,000/- as unexplained cash credit U/s. 68 of the Act. The Ld. AR submitted that the assessee has admitted that he has not maintained books of accounts and hence, the addition made U/s. 68 of the Act is unsustainable. Section

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 INCOME TAX OFFICER, WARD-1, , TUNI vs. MK AQUA HATCHERY, THONDANGI(M)

In the result, appeal of the revenue is dismissed

Bench: Shri N.K.Choudhry & Shri D.S. Sunder Singhआयकरअपीलसं./I.T.A.No.436/Viz/2019 (ननधधारण वर्ा/ Assessment Year:2015-16) Income Tax Officer Vs. M/S M.K.Aqua Hatchery Ward-1 D.No.3-36, Chintakayalapeta Tuni Thondangi (M) E.G.Dist. [Pan :Aazfm0955H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Smt.Suman Malik, Dr प्रत्यधथी की ओर से/ Respondent By : Shri G.V.N.Hari, Ar सुनवधई की तधरीख/ Date Of Hearing : 22.12.2020 घोर्णध की तधरीख/Date Of Pronouncement : 23.12.2020 आदेश /O R D E R Per Shri D.S.Sunder Singh: This Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) [Cit(A)], Rajamahendravaram In Itano.10128/2017-18/Ito,W-1,Tuni/Vsp/2018-19 Dated 21.03.2019 For The Assessment Year(A.Y.)2015-16 With The Delay Of 17 Days. The Assessing Officer Filed The Condonation Petition Giving Administrative Reasons For Delay. The Ld.Ar Expressed No Objection For Condoning The Delay. Therefore, The Delay Is Condoned & The Appeal Is Admitted.

68 of the Income Tax Act, 1961 (in short ‘Act’) which was deleted by the CIT(A. During the assessment proceedings, the Assessing officer( AO) found that the assessee is a partnership firm having 8 partners with Sri Ch.Mahankali as the main partner. All the partners together have contributed the share capital of Rs.2,25,50,000/- during the impugned

INCOME TAX OFFICER, VIZIANAGARAM vs. VIJAYANAGARAM WHEAT PRODUCTS PRIVATE LIMITED, KONDAKARAKAM

68\nr.w.s. 115BBE of the Act. The same documents were filed before Ld. CIT(A)\nby way of petition under Rule 46A of I.T. Rules. Ld. CIT(A) by exercising\nhis powers vested on him under section 250(4) of the Act has made the\nfollowing observations: -\nName of the\nparty\nGovind Rao\nLoan Amounts\nRs.49,50

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. So far as cash deposits of Rs.10,50,000/- is concerned, Ld.Pr.CIT directed the Ld. AO to examine