ARABOLU VENKATA NAGA DEEPATHI REPRESENTED BY POWER OF ATTORNEY HOLDER, N. SATYARAMANUJAMM ,VISAKHAPATNAM vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), VISAKHAPATNAM

In the result, the appeal fails and the same is hereby dismissed

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.178/Viz/2018 (ननधधारण वर्ा/ Assessment Year : 2010-11) Smt.Arabolu Venkata Naga Deepthi Vs. Income Tax Officer Rep. By Power Of Attorney Holder (International Taxation) Smt. N.Satyaramanujam Visakhapatnam Flat No.403, Dhanna Apartments Seethammadhara Visakhapatnam [Pan : Atcpa6413A] (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

short ‘Act’) on the payments made by him to the assessee. Subsequently, the assessee filed her income tax return for the A.Y.2010-11 on 17.05.2013 admitting sale consideration of Rs.39,69,000/-, towards her share on account of the above transfer of property and claimed exemption u/s 54F for the entire long term capital gains shown at Rs.17

VULLI RADHAKRISHNA,TUNI vs. INCOME TAX OFFICER, WARD-1, TUNI

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.359/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Vulli Radhakrishna, Vs. Income Tax Officer, Tuni. Ward-1, Pan: Aegpv1751H Tuni. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 17/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short “A.O.”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short “The Act”) Dated 26/03/2022 For Assessment Year (Ay) 2015-16. 2 Vulli Radhakrishna Vs. Ito

section 69A of the Act: Rs. 28,82,633/-; (ii) addition of unexplained payment of credit cards bills: Rs.11,79,160/-; (iii) unexplained investment towards purchase of equity shares: Rs.3,76,565/-; and (iv) short term capital gains (STCG) on sale of equity shares: Rs.1,68

GIRIJA DEVI KOMMAREDDY,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1). , VISAKHAPATNAM

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.188/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2014-15) Girija Devi Kommareddy Vs. Asst.Commissioner Of D.No.9-29-24/B, Cbm Compound Income Tax Balaji Nagar, Siripuram Circle-3(1) Visakhapatnam Visakhapatnam [Pan : Adfpk3441H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

68 r.w.s. 158BBE of the Income Tax Act and hence the appellant prays relief. 3. Ground No.1 is general in nature which does not require specific adjudication. 4. Ground No.3 is related to long term capital gains. Brief facts of the case are that the assessee is an individual, filed her return of income for the A.Y.2014-15, admitting total income

SARNALA SAYABABU,GUNTUR vs. THE INCOME TAX OFFICER, WARD-2(3), , GUNTUR

In the result, appeal of the asseseee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अऩीऱ सं./ I.T.A. No.98/Viz/2021 (ननधधारण वषा / Assessment Year : 2016-17) Sarnala Sayababu, Vs. Income Tax Officer, Guntur. Ward-2(3), Pan: Aheps 0990 A Guntur. (अऩीऱधथी/ Appellant) (प्रत्यथी/ Respondent) अऩीऱधथी की ओर से/ Appellant By : Sri Gvn Hari प्रत्यधथी की ओर से / Respondent By : Sri Mn Murthy Naik, Cit-Dr

capital gains‟ without giving the benefit of indexation of cost of acquisition. 6. Any other ground that may be urged at the time of appeal hearing.” 3. Brief facts of the case are that the assessee is an individual deriving income from house property & business filed his return of income declaring total income of Rs.8,08,260/- after claiming deduction

KAKRLA SURYA GANGADHAR TILAK,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, WARD-3(3), , VISAKHAPATNAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.177/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Smt.Kakarla Guna Vidya Saraswathi Vs. Income Tax Officer C/O Kakrla Surya Gangadhar Tilak Ward-3(3) A-1, Janani Apartments Visakhapatnam Pandurangaswamy Temple Backside Pandurangapuram Visakhapatnam [Pan : Apjpk5999N] आयकर अपील सं./I.T.A.No.178/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Sri Kakarla Surya Gangadhar Tilak Vs. Income Tax Officer A-1, Janani Apartments Ward-1(2) Pandurangaswamy Temple Backside Visakhapatnam Pandurangapuram Visakhapatnam [Pan : Ahbpk5319G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri I.Kama Sastry, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 27.02.2023 घोर्णध की तधरीख/Date Of Pronouncement : 31.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)]-1 Visakhapatnam

68,500/-. The immovable property was purchased by the co-owners for a consideration of Rs.24,00,000/- plus stamp duty and registration charges of Rs.5,14,795/- and registered vide document No.2910 of 2005 dated 24.06.2005. A notice u/s 148 of the Income Tax Act, 1961 (in short “Act”) dated 13.03.2014 was issued by the Assessing Officer

KAKARLA GUNA VIDYA SARASWATHI,,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, WARD-1(2), , VISAKHAPATNAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.177/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Smt.Kakarla Guna Vidya Saraswathi Vs. Income Tax Officer C/O Kakrla Surya Gangadhar Tilak Ward-3(3) A-1, Janani Apartments Visakhapatnam Pandurangaswamy Temple Backside Pandurangapuram Visakhapatnam [Pan : Apjpk5999N] आयकर अपील सं./I.T.A.No.178/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2007-08) Sri Kakarla Surya Gangadhar Tilak Vs. Income Tax Officer A-1, Janani Apartments Ward-1(2) Pandurangaswamy Temple Backside Visakhapatnam Pandurangapuram Visakhapatnam [Pan : Ahbpk5319G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri I.Kama Sastry, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 27.02.2023 घोर्णध की तधरीख/Date Of Pronouncement : 31.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)]-1 Visakhapatnam

68,500/-. The immovable property was purchased by the co-owners for a consideration of Rs.24,00,000/- plus stamp duty and registration charges of Rs.5,14,795/- and registered vide document No.2910 of 2005 dated 24.06.2005. A notice u/s 148 of the Income Tax Act, 1961 (in short “Act”) dated 13.03.2014 was issued by the Assessing Officer

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]

term Capital Gain of Rs.1,94,13,599/- which is disclosed in the return of income filed in response to notice under section 148 of the Act. In support of the above submissions, assessee filed relevant evidence in support Page. No 3 I.T.A.No.450/VIZ/2024 C.O. No. 17/VIZ/2024 Duvvuru Rekha Reddy of the funds mobilised for investment in the Company Steel

THE SRI GOWRI COOPERATIVE SOCIETY,VISAKHAPATNAM vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1,, VISAKHAPATNAM

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Blem/S. The Sri Gowri Vs. Pr.Cit-1, Co-Operative Society, Visakhapatnam. D.No.49-34-32/1, Konathala Complex, Akkayyapalem Main Road, Visakhapatnam. Pan No. Aaaat 8140 M (Appellant) (Respondent)

68 (Delhi), that the word "Banking" appearing in section 80P(2)(a)(i) cannot be given an extended and broad meaning and that to do so would be contrary to the ratio laid down in Totgars Co-operative Society. 24. In CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. MATTAPALLI RAMGOPAL, VISAKHAPATNAM

In the result, appeals of the revenue are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.65/Viz/2021 & 66/Viz/2021 (निर्धारण वर्ा / Assessment Year : 2014-15 & 2015-16) Asst.Commissioner Of Income Tax Vs. Mattapalli Ramgopal Circle-1(1) 25-8-246, Main Road Visakhapatnam Kurupam Market Visakhapatnam [Pan : Aarpw2133K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

short “Act”). Subsequently, the case was selected for scrutiny under CASS and accordingly, statutory notice u/s 143(2) of the Act was issued and served on the assessee. A survey operation u/s 133A of the Act was conducted in the business premises of the assessee on 09.01.2013. Accordingly, the AO has completed the assessment by determining the total income

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPTNAM vs. MATTAPALLI RAMGOPAL,, VISAKHAPATNAM

In the result, appeals of the revenue are dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.65/Viz/2021 & 66/Viz/2021 (निर्धारण वर्ा / Assessment Year : 2014-15 & 2015-16) Asst.Commissioner Of Income Tax Vs. Mattapalli Ramgopal Circle-1(1) 25-8-246, Main Road Visakhapatnam Kurupam Market Visakhapatnam [Pan : Aarpw2133K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

short “Act”). Subsequently, the case was selected for scrutiny under CASS and accordingly, statutory notice u/s 143(2) of the Act was issued and served on the assessee. A survey operation u/s 133A of the Act was conducted in the business premises of the assessee on 09.01.2013. Accordingly, the AO has completed the assessment by determining the total income

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

term “Surplus” is defined to mean the net excess of income over expenditure and hence the disposal of surplus signifies only “Appropriation of Profit”. 10. However, in our view, the impugned issue needs to be analysed in a different angle. In this connection, we feel it pertinent to discuss about the decision of Hon’ble Jurisdictional Andhra Pradesh High Court

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

term “Surplus” is defined to mean the net excess of income over expenditure and hence the disposal of surplus signifies only “Appropriation of Profit”. 10. However, in our view, the impugned issue needs to be analysed in a different angle. In this connection, we feel it pertinent to discuss about the decision of Hon’ble Jurisdictional Andhra Pradesh High Court

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

term “Surplus” is defined to mean the net excess of income over expenditure and hence the disposal of surplus signifies only “Appropriation of Profit”. 10. However, in our view, the impugned issue needs to be analysed in a different angle. In this connection, we feel it pertinent to discuss about the decision of Hon’ble Jurisdictional Andhra Pradesh High Court

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

term “Surplus” is defined to mean the net excess of income over expenditure and hence the disposal of surplus signifies only “Appropriation of Profit”. 10. However, in our view, the impugned issue needs to be analysed in a different angle. In this connection, we feel it pertinent to discuss about the decision of Hon’ble Jurisdictional Andhra Pradesh High Court

SRI UMA KAMANDALESWARA CO - OPERATIVE RURAL BANK LTD.,ATHREYAPURAM vs. THE ADDL. CIT,, KAKINADA

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Blesri Uma Kamandaleswara Vs. Addl.Cit, Kakinada Co-Op Rural Bank Ltd., Ryali, Range, Kakinada. Athreyapuram Mandalm, East Godavari District. Pan No. Aadas 4663 B (Appellant) (Respondent)

68 (Delhi), that the word "Banking" appearing in section 80P(2)(a)(i) cannot be given an extended and broad meaning and that to do so would be contrary to the ratio laid down in Totgars Co-operative Society. 24. In CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj

AGRI GOLD FOODS AND FARM PRODUCTS LIMITED,VIJAYAWADA vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

Bench: Us:

short, “Ld. CIT-DR”) objected to the seeking of condonation of the delay involved in the present appeal filed by the assessee company. 5. We have thoughtfully considered the contentions advanced by the Ld. Authorized Representatives for both parties regarding the delay involved in the filing of the present appeal before us. Although we are of the firm conviction that

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)

short “NFAC”], Delhi, relating to the assessment year 2021-22. 2. The assessee has pleaded the following grounds in the instant appeal : “1. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre erred in confirming the order passed & addition made at Rs.1,10,40,750/- by assessment unit U/s. 143(3) r.w.s. 144B of the I.T. Act, therefore

POTHINA SATYANARAYANA,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-2(5), VISAKHAPATNAM

In the result, appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.568/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Pothina Satyanarayana, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahdpp1312N Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 19/11/2025 Hearing: घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : 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 10/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 12/02/2024 For The Assessment Year 2018-19. The 2 Pothina Satyanarayana Vs. Ito

capital gains: Rs.4,48,23,073/-; (ii) addition under the head profit and gains from business or profession: Rs.2,37,686/-; and (iii) interest income: Rs.62,445/-. 4. Aggrieved, the assessee carried the matter in appeal before the CIT(A) who partly allowed the same. Ostensibly, the assessee had assailed the validity of jurisdiction that was assumed