LEWEK ALTAIR SHIPPING PRIVATE LIMITED,KAKINADA vs. DCIT, CIRCLE-1, KAKINADA

In the result, appeal filed by the assessee is allowed

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

6. We have carefully considered the rival submissions, perused the relevant material, including the orders of the lower authorities as well as the case laws referred at the time of hearing. Notably, the controversy before us primarily revolves around the applicability of transfer pricing provisions to the income that is covered by Chapter XII-G of the Act i.e. Tonnage

YADLA SRINIVASA RAO,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-3(2), , VIJAYAWADA

In the result, appeal of the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.78/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12) Yadla Srinivasa Rao Vs. Income Tax Officer D.No.20-04-190/7A Ward-3(2) Basavataraka Nagar Vijayawada Ayodhya Nagar Vijayawada [Pan : Abfpy5447F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, DC/AC 4(1), VISAKHAPATNAM

In the result, appeal filed by the assessee is partly allowed

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

2. That the Ld. Dispute Resolution Panel erred in not appreciating that the order of the Ld. JCIT (Transfer Pricing), Hyderabad passed under section 92CA of the Act is contrary to law and thus liable to be quashed. 3. That on the facts and in the circumstances of the case, the Ld. AO/Ld. TPO and the Ld. DRP erred

MANEPALLI RANADHEER,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-3(1),, VIJAYAWADA

In the result, appeals filed by the assessees for the A

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.256/Viz/2020 To 261/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2010-11 To 2015-16) Manepalli Ranadheer Vs. Income Tax Officer D.No.28-15-4, Arundalpet Ward-3(1) Vijayawada Vijayawada [Pan : Ahwpr5952K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No.19/Viz/2021 To 21/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12, 2012-13 & 2015-16) Late M.Pushpalatha Vs. Income Tax Officer Rep. By L/R Manepalli Ranadheer Ward-3(1) D.No.28-15-4, Arundalpet Vijayawada Vijayawada [Pan : Auepm8062C] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Mn Murthy Naik, Cit(Dr) सुनवधई की तधरीख / Date Of Hearing : 20.04.2023 घोर्णध की तधरीख/Date Of Pronouncement : 23.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessees Against The Orders Of The Principal Commissioner Of Income Tax (Appeals) [Pcit], Vijayawada Dated 19.02.2020 For The Assessment Year (A.Y.) 2010-11 To 2015-16 & The Order Dated 03.03.2020 For The A.Y. 2011-12, 2012-13 & 2015-16. 2

6. We have heard both the parties and perused the material placed on record. We find merit in the argument of the Ld.AR that the Ld.Pr.CIT has directed the AO to revise the assessment order passed on the proposal sent by the Ld.AO. In this connection, it is appropriate to quote section 263 of the Act which reads as follows

MANEPALLI RANADHEER,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-3(1),, VIJAYAWADA

In the result, appeals filed by the assessees for the A

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.256/Viz/2020 To 261/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2010-11 To 2015-16) Manepalli Ranadheer Vs. Income Tax Officer D.No.28-15-4, Arundalpet Ward-3(1) Vijayawada Vijayawada [Pan : Ahwpr5952K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No.19/Viz/2021 To 21/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12, 2012-13 & 2015-16) Late M.Pushpalatha Vs. Income Tax Officer Rep. By L/R Manepalli Ranadheer Ward-3(1) D.No.28-15-4, Arundalpet Vijayawada Vijayawada [Pan : Auepm8062C] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Mn Murthy Naik, Cit(Dr) सुनवधई की तधरीख / Date Of Hearing : 20.04.2023 घोर्णध की तधरीख/Date Of Pronouncement : 23.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessees Against The Orders Of The Principal Commissioner Of Income Tax (Appeals) [Pcit], Vijayawada Dated 19.02.2020 For The Assessment Year (A.Y.) 2010-11 To 2015-16 & The Order Dated 03.03.2020 For The A.Y. 2011-12, 2012-13 & 2015-16. 2

6. We have heard both the parties and perused the material placed on record. We find merit in the argument of the Ld.AR that the Ld.Pr.CIT has directed the AO to revise the assessment order passed on the proposal sent by the Ld.AO. In this connection, it is appropriate to quote section 263 of the Act which reads as follows

MANEPALLI RANADHEER,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-3(1),, VIJAYAWADA

In the result, appeals filed by the assessees for the A

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.256/Viz/2020 To 261/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2010-11 To 2015-16) Manepalli Ranadheer Vs. Income Tax Officer D.No.28-15-4, Arundalpet Ward-3(1) Vijayawada Vijayawada [Pan : Ahwpr5952K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No.19/Viz/2021 To 21/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12, 2012-13 & 2015-16) Late M.Pushpalatha Vs. Income Tax Officer Rep. By L/R Manepalli Ranadheer Ward-3(1) D.No.28-15-4, Arundalpet Vijayawada Vijayawada [Pan : Auepm8062C] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Mn Murthy Naik, Cit(Dr) सुनवधई की तधरीख / Date Of Hearing : 20.04.2023 घोर्णध की तधरीख/Date Of Pronouncement : 23.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessees Against The Orders Of The Principal Commissioner Of Income Tax (Appeals) [Pcit], Vijayawada Dated 19.02.2020 For The Assessment Year (A.Y.) 2010-11 To 2015-16 & The Order Dated 03.03.2020 For The A.Y. 2011-12, 2012-13 & 2015-16. 2

6. We have heard both the parties and perused the material placed on record. We find merit in the argument of the Ld.AR that the Ld.Pr.CIT has directed the AO to revise the assessment order passed on the proposal sent by the Ld.AO. In this connection, it is appropriate to quote section 263 of the Act which reads as follows

MANEPALLI RANADHEER,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-3(1),, VIJAYAWADA

In the result, appeals filed by the assessees for the A

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.256/Viz/2020 To 261/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2010-11 To 2015-16) Manepalli Ranadheer Vs. Income Tax Officer D.No.28-15-4, Arundalpet Ward-3(1) Vijayawada Vijayawada [Pan : Ahwpr5952K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No.19/Viz/2021 To 21/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12, 2012-13 & 2015-16) Late M.Pushpalatha Vs. Income Tax Officer Rep. By L/R Manepalli Ranadheer Ward-3(1) D.No.28-15-4, Arundalpet Vijayawada Vijayawada [Pan : Auepm8062C] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Mn Murthy Naik, Cit(Dr) सुनवधई की तधरीख / Date Of Hearing : 20.04.2023 घोर्णध की तधरीख/Date Of Pronouncement : 23.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessees Against The Orders Of The Principal Commissioner Of Income Tax (Appeals) [Pcit], Vijayawada Dated 19.02.2020 For The Assessment Year (A.Y.) 2010-11 To 2015-16 & The Order Dated 03.03.2020 For The A.Y. 2011-12, 2012-13 & 2015-16. 2

6. We have heard both the parties and perused the material placed on record. We find merit in the argument of the Ld.AR that the Ld.Pr.CIT has directed the AO to revise the assessment order passed on the proposal sent by the Ld.AO. In this connection, it is appropriate to quote section 263 of the Act which reads as follows

MANEPALLI RANADHEER,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-3(1),, VIJAYAWADA

In the result, appeals filed by the assessees for the A

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.256/Viz/2020 To 261/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2010-11 To 2015-16) Manepalli Ranadheer Vs. Income Tax Officer D.No.28-15-4, Arundalpet Ward-3(1) Vijayawada Vijayawada [Pan : Ahwpr5952K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No.19/Viz/2021 To 21/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12, 2012-13 & 2015-16) Late M.Pushpalatha Vs. Income Tax Officer Rep. By L/R Manepalli Ranadheer Ward-3(1) D.No.28-15-4, Arundalpet Vijayawada Vijayawada [Pan : Auepm8062C] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Mn Murthy Naik, Cit(Dr) सुनवधई की तधरीख / Date Of Hearing : 20.04.2023 घोर्णध की तधरीख/Date Of Pronouncement : 23.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessees Against The Orders Of The Principal Commissioner Of Income Tax (Appeals) [Pcit], Vijayawada Dated 19.02.2020 For The Assessment Year (A.Y.) 2010-11 To 2015-16 & The Order Dated 03.03.2020 For The A.Y. 2011-12, 2012-13 & 2015-16. 2

6. We have heard both the parties and perused the material placed on record. We find merit in the argument of the Ld.AR that the Ld.Pr.CIT has directed the AO to revise the assessment order passed on the proposal sent by the Ld.AO. In this connection, it is appropriate to quote section 263 of the Act which reads as follows

MANEPALLI RANADHEER,VIJAYAWADA vs. THE INCOME TAX OFFICER, WARD-3(1),, VIJAYAWADA

In the result, appeals filed by the assessees for the A

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.256/Viz/2020 To 261/Viz/2020 (ननधधारण वर्ा / Assessment Year : 2010-11 To 2015-16) Manepalli Ranadheer Vs. Income Tax Officer D.No.28-15-4, Arundalpet Ward-3(1) Vijayawada Vijayawada [Pan : Ahwpr5952K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकर अपील सं./I.T.A.No.19/Viz/2021 To 21/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12, 2012-13 & 2015-16) Late M.Pushpalatha Vs. Income Tax Officer Rep. By L/R Manepalli Ranadheer Ward-3(1) D.No.28-15-4, Arundalpet Vijayawada Vijayawada [Pan : Auepm8062C] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Mn Murthy Naik, Cit(Dr) सुनवधई की तधरीख / Date Of Hearing : 20.04.2023 घोर्णध की तधरीख/Date Of Pronouncement : 23.05.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessees Against The Orders Of The Principal Commissioner Of Income Tax (Appeals) [Pcit], Vijayawada Dated 19.02.2020 For The Assessment Year (A.Y.) 2010-11 To 2015-16 & The Order Dated 03.03.2020 For The A.Y. 2011-12, 2012-13 & 2015-16. 2

6. We have heard both the parties and perused the material placed on record. We find merit in the argument of the Ld.AR that the Ld.Pr.CIT has directed the AO to revise the assessment order passed on the proposal sent by the Ld.AO. In this connection, it is appropriate to quote section 263 of the Act which reads as follows

KOTARI SRINIVASA RAO, ,UNDRAJAVARAM MANDALAM vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, , RAJAHMUNDRY

In the result, additional ground raised is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.335/Viz/2019 (ननधधारण वर्ा / Assessment Year : 2014-15) Kotari Srinivasa Rao Vs. Principal Commissioner Of D.No.1-91, Canal Road Income Tax Velivennu Rajahmundry Undrajavaram Mandal West Godavari Dist. [Pan : Apjpk9870N] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

6. We have heard both the parties and perused the material placed on record. We find merit in the argument of the Ld.AR that the Ld.Pr.CIT has directed the AO to revise the assessment order passed on the proposal sent by the Ld.AO. In this connection, it is appropriate to quote section 263 of the Act which reads as follows

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

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

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./(I.T.)I.T.A.No.626/Viz/2018 (िनधा"रण वष" / Assessment Year : 2014-15) Teejay India Private Limited Vs. Asst.Commissioner Of Apsez, Pudimadaka Road Income Tax Atchutapuram Mandal Circle-5(1) Visakhapatnam Visakhapatnam [Pan : Aaaco9452H] (अपीलाथ"/ Appellant) (""थ"/ Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Darpan Kirpalani ""ाथ" की ओर से / Respondent By : Dr.Satyasai Rath, Cit(Dr) सुनवाई की तारीख / Date Of Hearing : 22.01.2024 घोषणा की तारीख/Date Of Pronouncement : 13.02.2024 आदेश /O R D E R Per Shri Balakrishnan S

2,700,626 on account of imputation of notional interest in outstanding receivables. Grounds for manufacturing and sale of fabric 4. On the fact and in the circumstances of the case and in law, with respect to adjustment to the transfer price of processing services, the learned DRP/AO/TPO erred in : 4.1. Rejecting the transfer pricing (TP) documentation maintained

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 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

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 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

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