DR KONDABOLU BASAVAPUNAIAH & DR LAKSHMI PRASAD TRUST,GUNTUR vs. INCOME TAX OFFICER (EXEMPTION WARD), GUNTUR

transferring the benefit, inter alia, of any property of the\nTrust to its Trustees by selling the property for a consideration which is less than\nadequate. As noted in the foregoing paragraphs, until the date of registration of\nthe sale deed on 12.05.2016, which was further rectified on 13.01.2018, the\nTrustee made a total payment of Rs. 1,50,50

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 is altogether is a different subject and has to be analysed within the ambit of law prescribed under section 92CA of the Act. TPO was also of the opinion that there is no direct benefit derived by the assessee commensurate to the payments of royalty and hence ALP of such payment for royalty be treated at either

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

transfer pricing is altogether is a different subject and has to be analysed\nwithin the ambit of law prescribed under section 92CA of the Act. TPO was\nalso of the opinion that there is no direct benefit derived by the assessee\ncommensurate to the payments of royalty and hence ALP of such payment for\nroyalty be treated at either

MDR CRANES & INFRASTRUCTURE PVT LTD,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

transfer of plant\nand machinery during the year. It was submitted that due to defaults of loans\ntaken by the Company the financiers seized the certain machinery kept as\nsecurity which was having a Written Down Value (WDV) in the books of\naccounts as on 01.04.2013 at Rs.7,24,84,687/-. Ld.AO further observed that\nassessee has reduced the value

3F INDUSTRIES LIMITED,TADEPALLIGUDEM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU

In the result, appeal of the assessee is partly allowed

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

TRANSFER PRICING MATTER: 1. Notional Guarantee fee on shareholders guarantee a. Making adjustment on the shareholders corporate guarantee is not covered under the loans availed by the AE, without appreciating the fact that the guarantee was provided for the benefit of the 3F Group. b. Not appreciating that the shareholder corporate guarantee is not covered under definition of international transaction

BRANDIX APPARAL INDIA PRIVATE LIMITED,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 5(1), VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed for

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No.627/Viz/2018 ("नधा"रणवष"/ Assessment Year : 2014-15) Brandix Apparel India Private Vs. Assistant Commissioner Of Limited, Income Tax, Apsez, Pudimadaka Road, Circle-5(1), Atchutapuram Mandal, Visakhapatnam. Visakhapatnam – 530011. Pan: Aaccb 6569 L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri Darpan Kriplani ""याथ"क"ओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr

50,882 Ltd Brandix Essentials Ltd Reimbursement of expenses 32,64,831 Brandix Apparel Ltd Reimbursement of expenses 37,82,725 Brandix Intimate Apparel Ltd Reimbursement of expenses 74,83,898 Brandix Apparel Ltd Recovery of Pre-commencement 3,68,47,180 Brandix Apparel Ltd Liability no longer required 9,91,13,198 3. Thereafter, the case was referred

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Transfer Pricing Officer (in short “TPO”) in respect of the revisionary order U/s. 263 of the Act. As per the directions of the Ld. Pr. CIT, Guntur, the Ld. TPO determined the ALP and made an adjustment of Rs. 2,05,39,000/- towards commission @ 2% on corporate guarantee given by the assessee to its 100% subsidiaries and passed

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, DUGGIRALA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Transfer Pricing Officer (in short “TPO”) in respect of the revisionary order U/s. 263 of the Act. As per the directions of the Ld. Pr. CIT, Guntur, the Ld. TPO determined the ALP and made an adjustment of Rs. 2,05,39,000/- towards commission @ 2% on corporate guarantee given by the assessee to its 100% subsidiaries and passed

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Transfer Pricing Officer (in short “TPO”) in respect of the revisionary order U/s. 263 of the Act. As per the directions of the Ld. Pr. CIT, Guntur, the Ld. TPO determined the ALP and made an adjustment of Rs. 2,05,39,000/- towards commission @ 2% on corporate guarantee given by the assessee to its 100% subsidiaries and passed

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

transfer pricing is altogether is a different subject and has to be analysed\nwithin the ambit of law prescribed under section 92CA of the Act. TPO was\nalso of the opinion that there is no direct benefit derived by the assessee\ncommensurate to the payments of royalty and hence ALP of such payment for\nroyalty be treated at either

3F INDUSTRIES LIMITED,TADEPALLIGUDEM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAMAHENDRAVARAM

In the result, appeal of the assessee is partly allowed

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

Transfer Pricing), Hyderabad for computation of Arm’s Length Price [ALP] of the transactions entered into by the assessee with its Associated Enterprises [AEs] outside India. The Ld. TPO in his report made U/s. 92CA(3) of the Act observed that during the year, the assessee has provided Corporate Guarantee on behalf of 3F Singapore and 3F Ghana

3F INDUSTRIES LIMITED,TADEPALLIGUDEM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.434/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2021-22) 3F Industries Limited V. Asst. Cit – Circle – 1 Aayakar Bhavan Pb No. 15, Tanuku Road Veerabhadrapuram Tadepalligudem, West Godavari Rajahmundry – 533105 Andhra Pradesh - 534102 Andhra Pradesh [Pan: Aaacf2643K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Transfer Pricing Officer ('TPO") and the Hon'ble Dispute Resolution Panel ('DRP') erred in: Ground No 1: Notional guarantee fee on shareholder's guarantee Making adjustment on the shareholders corporate guarantee provided to the banks for loans availed by the AE, without appreciating the fact that guarantee was provided for the benefit of the 3F Group. Ground No 2: Without

ARIMILLI RAMA KRISHNA,WEST GODAVARI DIST vs. ACIT, CIRCLE-1, RAJAHMUNDRY

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

Transfer Pricing Officer (TPO) were to be quashed. We further find that the Hon’ble High Court of Punjab & Haryana in the case of CIT vs. Nagendra Prasad (2013) 156 Taxmann.com 19 (Punjab & Haryana) had observed that where the notice was issued by AO under section 148 of the Act requiring the assessee to file a return within 30 days

TBR INFRA PVT LTD,ALAMPURAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

In the result, appeal of the assessee is allowed

50% of business promotion expenses\nofRs.46,10,888 claimed by the appellant.\n5. Any other ground that may be urged at the time of appeal\nhearing.\"\n5. Ground Nos. 1 & 5 are general in nature and needs no adjudication.\n6. Ground No.2 challenges the jurisdiction of the Ld. AO for issuance of\nnotice under section

3F INDUSTRIES LIMITED,TADEPALLIGUDEM vs. ASSISTANT COMMISSSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.275/Viz/2024 (िनधा"रणवष"/ Assessment Year :2020-21) 3F Industries Limited, Vs. Assistant Commissioner Of P.B. No. 15, Tanuku Road, Income Tax, Tadepalligudem, West Godavari Circle-1, District, Andhra Pradesh-534101. Rajahmundry. Pan: Aaacf2643K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Ms. Suvibha Nolkha, Ar ""याथ"क"ओरसे/ Respondent By : Dr. Satyasai Rath, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing : 07/10/2024 घोषणाक"तारीख/Date Of : 30/10/2024 Pronouncement O R D E R

Price [ALP] of the transactions entered into by the assessee with its Associated Enterprises [AEs] outside India. The Ld. TPO in his report made U/s. 92CA(3) of the Act observed that during the year, the assessee has provided Corporate Guarantee on behalf of its subsidiaries. The Ld. TPO also observed that the assessee has reported the same in Form

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

transferring it to the assessee company as investment in share capital. He therefore stated that the sources remained unexplained and hence the addition made by the Ld. CIT(A) be sustained. 11. We have heard the rival contentions and perused the material available on record. From the submissions made by the Ld.AR, we find from the summary of sworn statements

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

transferring it to the assessee company as investment in share capital. He therefore stated that the sources remained unexplained and hence the addition made by the Ld. CIT(A) be sustained. 11. We have heard the rival contentions and perused the material available on record. From the submissions made by the Ld.AR, we find from the summary of sworn statements

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

price of the\nstocks are artificially increased exponentially. Ld. AO after examining the\nSEBI reports which has levied penalty on the brokers involved in the trading\nobserved that these were nothing but accommodation entries. He also\n\nPage No. 5\n\nI.T (SS). A.No.10/VIZ/2025&I.T.A.No.136/VIZ/2025\nAshok Kumar Agrawal\nΙ.Τ.Α.No.150/VIZ/2025\nSantosh Agrawal\n\nreferred

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