M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

D E R Per Sanjay Arora, AM: This is a set of four Appeals by the Assessee agitating the part-allowance of it’s appeals contesting it’s assessments under section 153A (r/w s. 153C) r/w ss. 144 and 254 of the Income Tax Act, 1961 (the Act), dated 31.07.2014, for four years, being Assessment Years

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

D E R Per Sanjay Arora, AM: This is a set of four Appeals by the Assessee agitating the part-allowance of it’s appeals contesting it’s assessments under section 153A (r/w s. 153C) r/w ss. 144 and 254 of the Income Tax Act, 1961 (the Act), dated 31.07.2014, for four years, being Assessment Years

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

TDS u/s. 40(a)(ia) of the Act. In the said order, the AO had also stated that penalty proceedings u/s. 270A(1) of the Act would be initiated separately. The AO had not specifically mentioned under which limb underreporting was done by the assessee in view of the above said facts and circumstances of the case. The AO further

HI-LITE BUILDERS PRIVATE LIMITED ,KOZHIKODE vs. DCIT, CENTRAL CIRCLE-1, KOZHIKODE, KOZHIKODE

In the result, the appeal by the assessee is allowed

Bench: Smt. Beena Pillai & Ms. Padmavathy S.Assessment Year : 2009-10

D. That as per the amended provisions of Sec 40(a)(ia) of the IT Act, where TDS is deductible at source under Chapter XVIIB and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-Section (1) of Section 139, the expenses can be disallowed. E. That

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

D expenses within the scope of "Fee for technical Services under explanation 2 of section 9(1)(vii)of Income Tax Act and liable for TDS. 5.2 The Ld AO erred in not appreciating that the assessee company has made payment of Rs 1,07,08,950/- for clinical trials majorly to Apollo Tyres Middle East FZE on cost

MR. PREM MUKUNDAN ,ERNAKULAM vs. THE ITO WARD-2(2), KOCHI, KOCHI

In the result, appeals of the assessee are allowed

Bench: Shri George George K. (Judicial Member), Ms. Padmavathy S. (Accountant Member)

D E R Per: George George K., J.M. This appeal at the instance of the assessee is directed against the order of the CIT(A)/NFAC, Delhi dated 25.05.2022 passed under Section 250 of the Income Tax Act, 1961 (the Act). The relevant assessment year is 2011-12. 2. The assessee has raised the following grounds of appeal: - “1

ROSE GEORGE KOLLANUR,THRISSUR vs. ITO WARD 2(2), THRISSUR, THRISSUR

In the result, the appeal by the assessee is allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sassessment Year : 2014-15

D E R Per Padmavathy S, Accountant Member: This appeal is against the order of CIT (Appeals), National Faceless Assessment Centre, Delhi [NFAC] dated 16.3.2022 for the assessment year 2014-15. The assessee raised the following grounds of appeal:- “The amount of Rs. 74,86,271/- has been levied as additional capital gain and an exemption of only

INCOME TAX OFFICER(TDS), ALAPPUZHA vs. MUTHOOT HEALTH CARE PRIVATE LIMITED, KOZHENCHERRY

Accordingly, we decline to interfere with the same. Thus, Ground No.1 to 4 raised by the Revenue are dismissed

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI RAHUL CHAUDHARY (Judicial Member)

TDS, Aayakar Bhavan, Beach Road, Alappuzha, Kerala-688001 …………. Appellant Vs Muthoot Health Care Pvt. Ltd. College Road, Kozhencherry, Patahanamthitta, Kerala-689641. [PAN:TVDM01878C] …………. Respondent Appearance For the Appellant/Department : Shri Thomson Thomas, CA For the Respondent/Assessee : Smt. Leena Lal, Sr. DR Date Conclusion of hearing : 20.08.2025 Pronouncement of order : 27.10.2025 O R D E R [ Per Rahul Chaudhary, Judicial Member: 1

VADAKKEVILA SERVICE CO-OPERATIVE BANK LTD,KOLLAM vs. THE ITO, KOLLAM

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

13 ITA No.478/Coch/2023. Vadakkevila SCB Ltd. society to a banking company if it is a co-operative bank within the meaning of the said provision. This is because Chapter V of the BR Act, 1949, deals with application of the Chapter to co-operative societies which are co-operative banks within the meaning of the said chapter. For the purpose

M/S.KERALA STATE WAREHOUSING CORPN,ERNAKULAM vs. THE ACIT, KOCHI

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Kerala State Warehousing Vs Acit, Corporate Circle 1(2) Corporation Is Press Road Kochi 682018 Pb No. 1727, Warehousing Corporation Road Ernakulam 682016 Pan – Aabck1583G (Appellant) (Respondent) Assessee By: Shri K. Gopi, Ca Revenue By: Shri Shantam Bose, Cit Dr

d) It is further submitted that the no due date has been prescribed under the above Regulations for the remittance of the employee contributions. This fact has been verified and confirmed by the assessing officer while completing the order u/s 143 (3) consequent to the order u/s 263 of the Act passed by the Pr. CIT. Annexure-2. (Refer Para

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

D E R Per: Inturi Rama Rao, AM These are appeals filed by the assessee against different orders of Commissioner of Income Tax (Appeals)-3, Kochi [CIT(A)] dated 25.04.2025 for Assessment Years (AY) 2006-07, 2013-14 & 2010-11. 2. Since identical issues and facts are involved in these appeals, they are heard together and disposed of by this

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

D E R Per: Inturi Rama Rao, AM These are appeals filed by the assessee against different orders of Commissioner of Income Tax (Appeals)-3, Kochi [CIT(A)] dated 25.04.2025 for Assessment Years (AY) 2006-07, 2013-14 & 2010-11. 2. Since identical issues and facts are involved in these appeals, they are heard together and disposed of by this

MUTHOOT FINCORP LIMITED,TRIVANDRUM vs. ITO,CIRCLE CENTRAL, TRIVANDRUM

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

D E R Per: Inturi Rama Rao, AM These are appeals filed by the assessee against different orders of Commissioner of Income Tax (Appeals)-3, Kochi [CIT(A)] dated 25.04.2025 for Assessment Years (AY) 2006-07, 2013-14 & 2010-11. 2. Since identical issues and facts are involved in these appeals, they are heard together and disposed of by this

SRI. GEORGE MATHEW,COCHIN vs. THE ITO, COCHIN

In the result, appeal of the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahuteam Sustain Cr Building Vs. Plot No. 71, Mra I.S. Press Rod Kakkanadu, Kochi 682030 Kochi 682018 Pan – Adwpm1819L Appellant Respondent

TDS liability may arise if composite bills have been issued.” “1. The learned Commissioner of Income Tax (Appeals) has erred in sustaining the addition of Rs. 25,00,000/- made by the assessing officer treating Agricultural Income as Business Income. 2. The learned Commissioner of Income Tax (Appeals) has erred in sustaining the addition of 10% of expenses amounting

THE ACIT, COCHIN vs. SRI. GEORGE MATHEW, COCHIN

In the result, appeal of the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahuteam Sustain Cr Building Vs. Plot No. 71, Mra I.S. Press Rod Kakkanadu, Kochi 682030 Kochi 682018 Pan – Adwpm1819L Appellant Respondent

TDS liability may arise if composite bills have been issued.” “1. The learned Commissioner of Income Tax (Appeals) has erred in sustaining the addition of Rs. 25,00,000/- made by the assessing officer treating Agricultural Income as Business Income. 2. The learned Commissioner of Income Tax (Appeals) has erred in sustaining the addition of 10% of expenses amounting

THE KAREEPPA PANCHAYATH SERVICE CO-OPERATIVE BANK LTD.D,KOLLAM vs. THE ITO, KOLLAM

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhassessment Year : 2017-18

13 Kareeppa Panchayat Service Co-op. Bank Ltd. \ defined in Section 5(b) of the said Act to mean the accepting, for the purpose of lending or investment, of deposits of money from the public, repayable on demand or otherwise, and withdrawal by cheque, draft, order or otherwise. Therefore, a banking company must transact banking business

IFTHIKAR KARUPPAMVEETIL ABDUL RAHMAN,CHAVAKKAD vs. ITO, INTERNATIONAL TAXATION, KOCHI

Appeal is partly allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

D. Without prejudice to the above submission it is respectfully submitted that, On the facts and in the circumstances of the case and in law, theassessment order framed under section 143(3) read with section 144C( 13) of the Income-tax Act, 1961 ('the Act) passed by the Learned Assessing officer dated 21.12.2023 incorporating directions of the Hon'ble Dispute

BATHX BATHWARE INDIA PRIVATE LIMITED,COCHIN vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming