ASSISTANT COMMISSIONER OF INCOME, CIRCLE-1(1),, GUNTUR vs. M/S CCL PRODUCTS(INDIA) LIMITED, GUNTUR

In the result, appeal of the revenue is dismissed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.348/Viz/2018 (ननधधारण वर्ा/ Assessment Year:2014-15) Dcit, Circle-1(1) Vs. M/S Ccl Products (India) Guntur Pvt. Ltd. Duggirala Post & Mandal Guntur [Pan : Aaacc9552G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Dr प्रत्यधथी की ओर से/ Respondent By : Shri Ramesh Babu, Ar सुनवधई की तधरीख / Date Of Hearing : 20.03.2019 घोर्णध की तधरीख/Date Of Pronouncement : 03 .04.2019

Section 92C of the Income-tax Act, 1961 - Transfer pricing - Computation of arm's length price (Comparables and Adjustments/Adjustments - Interest) - Assessment year 2011-12 - TPO noted that there was delay in receipt of payment from AE and observed that estimate period of 30 days would be considered as normal period for inter-company sales and services and any delay beyond

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. VENKATRAMA POULTRIES PVT. LTD, GUNTUR

price per egg accordingly.”\n17. We are in agreement with the findings of the Ld. CIT(A) and hence we do\nnot find any interference is required in the decision of the Ld. CIT(A). Thus,\nGround Nos. 2, 3 & 4 raised by the revenue are dismissed.\n18. With regard to estimating the unaccounted income @30% on the total\nsuppressed

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

transfer of thermal heat energy from steam to the juices. The dispute between the revenue and the assessee arose whether the receipts from generation and supply of steam was eligible for relief under section 801A and according to the revenue, the steam was not the power, which was eligible for tax holiday under section 801A. 7.11The word power

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

transfer of thermal heat energy from steam to the juices. The dispute between the revenue and the assessee arose whether the receipts from generation and supply of steam was eligible for relief under section 801A and according to the revenue, the steam was not the power, which was eligible for tax holiday under section 801A. 7.11The word power

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

transfer of thermal heat energy from steam to the juices. The dispute between the revenue and the assessee arose whether the receipts from generation and supply of steam was eligible for relief under section 801A and according to the revenue, the steam was not the power, which was eligible for tax holiday under section 801A. 7.11The word power

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1),, VISAKHAPATNAM vs. SRI Y VENKANA CHOUDARY,, VISAKHAPATNAM

In the result, appeal filed by the Revenue as well as the cross objection filed by the assessee are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleacit, Circle-4(1), Vs. Y. Venkanna Choudary, Visakhapatnam. D.No. 1-1-2, C/O Anuradha Auto Centre, Sheela Nagar, Nh-5, Visakhapatnam. Pan No. Aanpy 3003 G (Appellant) (Respondent) C.O.No. 108/Viz/2019 (Arising Out Of Ita No. 272/Viz/2018) (Asst. Year : 2014-15) Y. Venkanna Choudary, Vs. Acit, Circle-4(1), D.No. 1-1-2, C/O Anuradha Visakhapatnam. Auto Centre, Sheela Nagar, Nh-5, Visakhapatnam. Pan No. Aanpy 3003 G (Appellant) (Respondent)

29,41,90,834/- Total Liabilities (L) Rs. 19,19,05,428/- Net value (A – L) Rs. 10,22,85,406/- Paid up value of equity capital Rs. 8,50,42,600/- Fair market value (A-L)*PE/PV Rs. 12.02/- Value of 4,25,000 shares Rs. 1,08,78,100/- Face value of shares Rs. 90,50,000/- Difference

MAHATI SOFTWARE PVT LTD.,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, appeals of the assessee are partly allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.67/Viz/2016 & 68/Viz/2017 (निर्धारण वर्ा/Assessment Year:2011-12 & 2012-13) M/S Mahati Software Pvt. Ltd. Vs. Asst. Commissioner Of D.No.10-27-14A Income Tax Sivam, Kailashmetta Circle-3(1) Waltair Visakhapatnam Visakhapatnam [Pan : Aadcm9620J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

transfer pricing document that the assessee has given adavances to the AE, Greatwater Software Inc towards patient point project(PPK) for an amount of Rs.18,44,00,935/- but not charged any interest on the advances given to the AE. The TPO also observed that the similar advance was given in the immediately preceding assessment year also. Thus, the opening

M/S. MAHATI SOFTWARE PVT. LTD.,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, appeals of the assessee are partly allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.67/Viz/2016 & 68/Viz/2017 (निर्धारण वर्ा/Assessment Year:2011-12 & 2012-13) M/S Mahati Software Pvt. Ltd. Vs. Asst. Commissioner Of D.No.10-27-14A Income Tax Sivam, Kailashmetta Circle-3(1) Waltair Visakhapatnam Visakhapatnam [Pan : Aadcm9620J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

transfer pricing document that the assessee has given adavances to the AE, Greatwater Software Inc towards patient point project(PPK) for an amount of Rs.18,44,00,935/- but not charged any interest on the advances given to the AE. The TPO also observed that the similar advance was given in the immediately preceding assessment year also. Thus, the opening

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Transfer Pricing adjustment as per the order passed by the TPO under section 92CA(3) of the Act dated 31.10.2023: Rs.21,90,56,110/-. 8. The assessee-company aggrieved with the order passed by the A.O under Section 143(3) r.w.s 144C(13) r.w.s 144B of the Act, dated 30.10.2024, has carried the matter in appeal before

SNF (INDIA) PRIVATE LIMITED,VISAKHAPATNAM vs. DCIT/ACIT, CIRCLE - 3(1), VISAKHAPATNAM

In the result, appeal of the revenue is dismissed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.204/Viz/2025 (निर्धारणवर्ा/ Assessment Year:2016-17) Vs. M/S. Snf (India) Private Limited Dcit - Circle – 3(1) 19 Jnpc, Ramky Pharmacity Income Tax Office Paravada, Visakhapatnam – 531021 Infinity Towers, Sankarmat Road Andhra Pradesh Visakhapatnam – 530016 Andhra Pradesh [Pan:Aaacp4070A]

Transfer Pricing officer)-1, Hyderabad passed an order under section 92CA(3) of the Act on 29.10.2019 vide Order No. ITBA/TPO/F/92CA3/2019-20/1019531492(1) for the A.Y. 2016-17. The assessee has entered into the international transactions as follows: Associated Nature of Amount Paid Amount Enterprises International/Domestic Payable Received/Receivable Transactions (Amount in (Amount in INR) INR) Purchase of various

GVK POWER & INFRASTRUCTURE LIMITED,KADIYAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, RAJAHMUNDRY

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकरअपीलसं./I.T.A.No.553/Viz/2018 (ननधधारण वर्ा/Assessment Year:2014-15) M/S Gvk Power & Infrastructure Ltd. Vs. Asst.Commissioner Of D.No.5-48, Gvk Power Plant Income Tax Jegurupadu, Kadiyammandal Circle-2(1) East Godavari Rajamahendravaram [Pan :Aaacj5599A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओ रसे/ Appellant By Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से/ Respondent By Shri D.K.Sonowal, Cit Dr सुनवधई की तधरीख / Date Of Hearing : 21.03.2019 घोर्णध की तधरीख/Date Of Pronouncement : 03.04.2019

10. The next contention of the assessee is with regard to the disallowance u/s 14A of the Act. The Ld.AR argued that though the assessee had offered the expenditure relatable to the dividend income for taxation in the original return, the assessee had detected the mistake subsequently and filed the revised return withdrawing disallowance of interest and processing charges relating

DCIT, CIRCLE - 3(1), VISAKHAPATNAM vs. SNF INDIA PRIVATE LIMITED, VISAKHAPATNAM

pricing), Hyderabad on 15.11.2018 after obtaining\napproval from the Appropriate Authorities. Accordingly, the Dy.CIT (Transfer\nPricing officer)-1, Hyderabad passed an order under section 92CA(3) of the Act\non 29.10.2019 vide Order No. ITBA/TPO/F/92CA3/2019-20/1019531492(1)\nfor the A.Y. 2016-17. The assessee has entered into the international\ntransactions as follows:\nAssociated\nEnterprises\nNature of\nInternational/Domestic\nTransactions\nAmount\nReceived/Receivable

DEPUTY COMMISSIONER OF INCOME TAX (IT), VISAKHAPATNAM vs. SHRI APPARAO MUKKAMALA, USA

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

transfer of 1,06,900 shares by the assessee at Rs. 657 per share for a total consideration of Rs. 7,02,33,300. 4. On the other hand, the seized scribbling contained entries which the department construed as cash payments to certain persons, including the assessee. The noting in the seized scribblings mentioned, viz. “18/08/2015 – 100 cash Appa

DCIT, CIRCLE - 3(1), VISAKHAPATNAM vs. SNF INDIA PRIVATE LIMITED, VISAKHAPATNAM

pricing), Hyderabad on 15.11.2018 after obtaining\napproval from the Appropriate Authorities. Accordingly, the Dy.CIT (Transfer\nPricing officer)-1, Hyderabad passed an order under section 92CA(3) of the Act\non 29.10.2019 vide Order No. ITBA/TPO/F/92CA3/2019-20/1019531492(1)\nfor the A.Y. 2016-17. The assessee has entered into the international\ntransactions as follows:\nAssociated\nEnterprises\nNature of\nInternational/Domestic\nTransactions\nAmount\nReceived/Receivable

VIJAPURAPU SUDHA RAO,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-3(1), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

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

10,26,020/-. Thereafter, the return was summarily processed by the CPC, Bengaluru and an order U/s. 143(1) of the Act was passed on 1/11/2017. Subsequently, the assessee filed his revised return of income on 1/11/2017 declaring total income of Rs.44,81,290/- which includes capital gains of Rs. 34,65,000/- on sale of vacant site admeasuring

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR vs. VENKATRAMA POULTRIES PVT. LTD., GUNTUR

price per egg accordingly.”\n17.\nWe are in agreement with the findings of the Ld. CIT(A) and hence we do\nnot find any interference is required in the decision of the Ld. CIT(A). Thus,\nGround Nos. 2, 3 & 4 raised by the revenue are dismissed.\n18.\nWith regard to estimating the unaccounted income @30% on the total\nsuppressed

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR vs. VENKATRAMA POULTRIES PVT LTD, GUNTUR

price per egg accordingly.\"\n17. We are in agreement with the findings of the Ld. CIT(A) and hence we do\nnot find any interference is required in the decision of the Ld. CIT(A). Thus,\nGround Nos. 2, 3 & 4 raised by the revenue are dismissed.\n18. With regard to estimating the unaccounted income @30% on the total\nsuppressed

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR vs. VENKATRAMA POULTRIES PVT. LTD., GUNTUR

price per egg accordingly.”\n17. We are in agreement with the findings of the Ld. CIT(A) and hence we do\nnot find any interference is required in the decision of the Ld. CIT(A). Thus,\nGround Nos. 2, 3 & 4 raised by the revenue are dismissed.\n18. With regard to estimating the unaccounted income @30% on the total\nsuppressed