MANNE SUBBA RAO,RAJAMAHENDRAVARAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), , RAJAMAHENDRAVARAM

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

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.158/Viz/2018 (धििाारण िर्ा/ Assessment Year: 2014-2015) Manne Subba Rao Acit, Circle-2(1) D.No.78-15-21/5,T-1, Rajamahendravaram Block-1, Rama Residency Syamala Nagar Rajamahendravaram [Pan : Ayyps 3433R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलार्थी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यार्थी की ओर से/ Respondent By : Smt. Suman Malik, Dr

4. The transfer must be for some consideration u/s. 48 of the Act. 5. The consideration must be in monetary terms. 6. Profits or gains must arise by way of transfer. 5.4. Section 45(2) creates fiction with regard to "consideration" u/s. 48 of the Act. Generally there will be no capital gains without consideration for transfer of capital asset

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

4 I.T.A. No.348/Viz/2018 M/s CCL Products (India) Ltd., Guntur cannot be applied straight away. In that case, the assessee company M/s. Logix Micro Systems Ltd., (Logix India' for short) is having an AE in USA as 100% subsidiary known as Logix America Inc. USA (Logix USA for short). Logix USA in turn holds 76% of the shares in another

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

VISAKHAPATNAM PORT AUTHORITY, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

THE VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASST. CIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

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

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

ASST. COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. FYSOLATE TECHNOLOGIES, VIJAYAWADA

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.182/Viz/2023 (िनधा"रण वष" / Assessment Year : 2017-18) Assistant Commissioner Of Vs. Fysolate Technologies, Income Tax, Vijayawada. Vijawayada. Pan: Aacff5633L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Mithilesh Sannareddy ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 16/04/2024 घोषणा क" तारीख/Date Of : 15/07/2024 Pronouncement O R D E R

Transfer Pricing Officer [“Ld. TPO”] issued notices on various dates U/s. 92CA of the Act. In response, the assessee furnished the information as called for along with the T.P. Documentation. The assessee claimed deduction U/s. 10AA of the Act. The domestic transactions reflected in 3CEB/T.P. Study report are as follows: Description In Rs. Purchase of crude Herbal Extracts and oils

DEPUTY COMMSSIONER OF INCOME TAX, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, VISAKHAPATNAM

In the result, appeal filed by the revenue is dismissed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.100/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) Visakhapatnamportauthority Vs. Theasst.Cit -Circle-1(1) Administrative Office Building 4 Th Floor, Prathyakshkar Bhavan Port Area, Visakhapatnam 530001 Mvp Road, Beside Post Office Andhra Pradesh-530001. Sector-8, Mvp Colony Visakhapatnam – 530017 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.103/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) The Dy.Cit Vs. Visakhapatnamportauthority Room No. 412, 4 Th Floor Administrative Office Building Prathyakshkar Bhavan Port Area, Visakhapatnam 530035 Mvp Double Road Andhra Pradesh Opp. Rythubazar Visakhapatnam – 530014 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VISAKHAPATNAM

In the result, appeal filed by the revenue is dismissed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.100/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) Visakhapatnamportauthority Vs. Theasst.Cit -Circle-1(1) Administrative Office Building 4 Th Floor, Prathyakshkar Bhavan Port Area, Visakhapatnam 530001 Mvp Road, Beside Post Office Andhra Pradesh-530001. Sector-8, Mvp Colony Visakhapatnam – 530017 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.103/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) The Dy.Cit Vs. Visakhapatnamportauthority Room No. 412, 4 Th Floor Administrative Office Building Prathyakshkar Bhavan Port Area, Visakhapatnam 530035 Mvp Double Road Andhra Pradesh Opp. Rythubazar Visakhapatnam – 530014 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section

VISAKHAPATNAM PORT AUTHORITY,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VISAKHAPATNAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.191/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2009-10) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.193/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Visakhapatnam Port Authority, Vs. The Asst. Commissioner Of Administrative Office Building, Income Tax, Port Area, Visakhapatnam, Circle-1(1), Andhra Pradesh-530001. Visakhapatnam. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.200/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Deputy Commissioner Of Income Vs. Visakhapatnam Port Authority, Tax, Circle-1, Range-1, Administrative Office Building, Visakhapatnam. Port Area, Visakhapatnam, Andhra Pradesh-530001. Pan: Aaalv 0035 C (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent)

transferred to the lessee. It was submitted by the Ld. AR that in the mercantile system of accounting being regularly followed by the assessee recognizing the rent 9 which was received on upfront for a period of 30 years over the lease period is in accordance with the accounting policy and also complying with the provisions of section