M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,ERNAKULAM 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

139 as applicable in the case of the assessee. Explanation 2.—In this sub-section, "tax on total income as determined under sub- section (1) of section 143" shall not include the additional income-tax, if any, payable under section 143. Explanation 3.—Where, in relation to an assessment year, an assessment is made for the first time under section

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

139 as applicable in the case of the assessee. Explanation 2.—In this sub-section, "tax on total income as determined under sub- section (1) of section 143" shall not include the additional income-tax, if any, payable under section 143. Explanation 3.—Where, in relation to an assessment year, an assessment is made for the first time under section

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

139 as applicable in the case of the assessee. Explanation 2.—In this sub-section, "tax on total income as determined under sub- section (1) of section 143" shall not include the additional income-tax, if any, payable under section 143. Explanation 3.—Where, in relation to an assessment year, an assessment is made for the first time under section

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

139(1). Accordingly, the AO made an addition of Rs.74,86,271 while completing the assessment u/s. 143(3). Aggrieved, the assessee filed the appeal before the CIT(A), who upheld the order of the AO. Aggrieved, the assessee is in appeal before the Tribunal. 3. The ld. AR submitted that the assessee has claimed the deduction u/s. 54F based

THANNERMUKKOM SERVICE COOPERATIVE SOCIETY LIMITED,ALAPPUZHA vs. ITO WARD 1 & TPS, ALAPPUZHA, ALAPPUZHA

Bench: Shri Satbeer Singh Godaraand Shri Manoj Kumar Aggarwal

TDS Limited, No.A 809, Alappuzha Thannermukkom North, Vs. Thannermukkom, Cherthala, Alappuzha, Kerala. PIN 688527 PAN –AACAM1602K Appellant Respondent Appellant by: Shri Kabil Chandran, Adv Respondent by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 09.11.2022 Date of Pronouncement: 13.12.2022 O R D E R Per: S.S. Godara, J.M. These assessee’s twin appeals for A.Ys

THANNERMUKKOM SERVICE COOPERATIVE SOCIETY LIMITED,ALAPPUZHA vs. ITO WARD 1 & TPS, ALAPPUZHA, ALAPPUZHA

Bench: Shri Satbeer Singh Godaraand Shri Manoj Kumar Aggarwal

TDS Limited, No.A 809, Alappuzha Thannermukkom North, Vs. Thannermukkom, Cherthala, Alappuzha, Kerala. PIN 688527 PAN –AACAM1602K Appellant Respondent Appellant by: Shri Kabil Chandran, Adv Respondent by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 09.11.2022 Date of Pronouncement: 13.12.2022 O R D E R Per: S.S. Godara, J.M. These assessee’s twin appeals for A.Ys

INCOME TAX OFFICER, WARD 1 AND TPS, KANNUR vs. KANNUR BUILDING MATERIALS CO OPERATIVE SOCIETY LIMITED, PAPPINISSERY, KANNUR

In the result, the appeal filed by the revenue ITA No

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2013-14 The Income Tax Officer, Ward 1 & Tps .......... Appellant Aayakar Bhavban, Chovva P.O., Kannur 670006 Vs. Kannur Building Materials Co-Op. Society Ltd .......... Respondent No. C 1741, Pappinissery P.O., Kannur 670561 [Pan: Aaaak7151K]

139(1) of the Act. The assessee’s case was selected for scrutiny. The assessee during the impugned assessment year engaged in sand mining and selling. The object of the society to control the spending, to encouragement investment, self-sufficiency, co-operative attitude among members of the society and also to take measures to improve the financial, educational and overall

KERALA STATE COOPERATIVE EMPLOYEES PENSION BOARD,THIRUVANANTHAPURAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTION CIRCLE, THIRUVANANTHAPURAM

In the result, the appeal filed by the assessee is dismissed

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

TDS and refund due to the appellant. Admittedly, the appellant had not filed return of income either voluntarily under the provisions of section 139(1) of the Act or in response to the notice issued u/s. 142(1) of the Act. Thus there was no valid return of income for claiming refund as stipulated under the provisions of section

DJ AMUSEMENTS,8/58 8/58 ,CHATHANKANDATH HOUSE vs. INCOME TAX OFFICER, PALAKKAD

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

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Hon’Ble Manu Kumar Giriआयकर अपील सं./ Ita No.758/Coch/2025 "नधा"रण वष" /Assessment Year: 2014-15 Dj Amusements, The Income Tax Officer, Mankara P.O, Vs. Ward-1 & Tps, Palakkad – 678 614. Palakkad. Kerala Pan: Aahfd 2211P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Sivadas Chettoor, C.A ""यथ" क" ओर से /Respondent By : Smt Leena Lal, Snr Ar सुनवाई क" तार"ख/Date Of Hearing : 06.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 28.11.2025 आदेश / O R D E R Per Manu Kumar Giri ():

139. 3. The assessee contended that the rent payments were made to Punalur Municipality and Orkkatteri Panchayat, both of which are “local authorities” as defined under Section 10(20) of the Act. Therefore, in view of the binding CBDT Circular, no TDS was deductible, and consequently, the order passed under Sections 201(1) and 201(1A) is unsustainable

MR. RANJITH THAZHE KUNHAMBATH,ERNAKULAM vs. ITO, WARD 3(3), NON CORPORATE RANGE 2, KOCHI

In the result, the appeal is allowed in favour of the assessee and the stay petition is dismissed as infructuous

Bench: Shri George George K & Ms. Padmavathy S

139(1). As per Form No. 16 issued subsequently by M/s. HDFC Bank Limited, TDS has been remitted on 06-05-2010 to the Government Account as per challan no. 05194. During the course of hearing the assessee admitted the omission to offer the perquisite value of ESOP to tax. The accordingly concluded the u/s 143(3) assessing the total

TRESA JOLLY,ERNAKULAM vs. DCIT , INTERNATIONAL TAXATION, KOCHI

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

Bench: Shri Chandra Poojari & Shri Soundararajan K

TDS amount deducted by the employer. Thereafter, the case was selected for scrutiny by CASS and notice u/s.143(2) of the Income-tax Act, 1961 (“the Act” for short) was issued, for which the assessee furnished copy of acknowledgement for filing revised return and the annexure filed along with the return and declared her residential status as resident and withdrew

CLINT MARTEL WILFRED,ERNAKULAM vs. COMMISSIONER OF INCOME TAX APPEAL CIT (A) BENGALURU - 12, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Clint Martel Wilfred Dcit (Interational Taxation) Clint Dale, Moolankuzhy Kochi Vs. Nazreth, Ernakulam 682002 [Pan: Abnpw6970H] (Appellant) (Respondent)

139 of the Act for the year under consideration. The AO noticed that there were cash deposits in the bank of the assessee. Accordingly, the AO issued notice under section 148 of the Act and 2 Clint Martel Wilfred thus the assessment proceedings under section 147 of the Act was initiated. During the assessment proceeding, the assessee was asked

PALMSHORE HOTELS PRIVATE LIMITED,THIRUVANANTHAPURAM vs. ASST COMMISSIONER OF INCOME TAX, CIRCLE 1(), THIRUVANANTHAPURAM

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

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

section 139(1) of the Income Tax Act, 1961 (the Act) was filed for AY 2017-18. However, the AO, on 2 Palmshore Hotels Pvt. Ltd. receipt of information that the appellant had a turnover from services reported in Service Tax Return of Rs. 34,17,888/-, interest income and rental income on which TDS was deducted, formed an opinion

ELOOR VANITHA KSHEMODHARANA CO-OPERATIVE SOCIETY LTD.,UDYOGAMANDAL vs. ITO WARD -1 &TPS, ALUVA

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

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2019-20 Eloor Vanitha Kshemodharana Co-Op Society Ltd. ......... Appellant Fact Dormetry Room No. 27, Kochi 683501 [Pan: Aaaae8921H] Vs. The Income Tax Officer, Wd-1 & Tds, Aluva .......... Respondent Assessee By: Shri K.K. Joseph, Ca Revenue By: Ms. Neethu S. Sr. Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 11.09.2025 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. No Return Of Income For Ay 2019-20 Was Filed By The Appellant Society Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). Notice U/S. 148 Of The Act Was Issued To The Appellant On 30.03.2023. In Response To The Notice U/S. 148 The Appellant Filed Return Of Income On 06.06.2023 Declaring

TDS, Aluva .......... Respondent Assessee by: Shri K.K. Joseph, CA Revenue by: Ms. Neethu S. Sr. DR Date of Hearing: 27.11.2025 Date of Pronouncement: 28.11.2025 O R D E R This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi [CIT(A)] dated 11.09.2025 for Assessment Year (AY) 2019-20. 2. Brief facts

ABDUL SALAM PAREETHUKUNJU,PUNALUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE , KOLLAM, KOLLAM

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahushri Abdul Salam Pareethu Kunju Acit, Circle Kollam Malika Veettil Agencies Aayakar Bhavan Vs. Near Power House Near Karbala Junction Punalur 691305 Kollam 691001 Pan – Acupk4194P Appellant Respondent

Section 40(a)(ia) of the Income Tax Act, 1961 (hereinafter "the Act"). The assessee has reduced profit of Rs.10,21,126/- from his computation under ICDS but he was unable to file any document/working of ICDS during the course of assessment proceedings. Accordingly the AO added the sum to the total income of the assessee. The assessee has also

NELLIPARAMBIL GOPALAN GANGADEVI,ERNAKULAM vs. ITO WARD 1, ALUVA

In the result, the assessee’s appeal is dismissed and the stay application is dismissed as infructuous

Bench: Shri Sanjay Arora & Shri Manomohan Das

139 ITD 526 (Bang)), since upheld by the Hon'ble Karnataka High Court [in [2013] 356 ITR 468 (Kar)], as well as by the Cochin Bench in Krishnan Achary vs. ITO (ITA No. 432/Coch/2018, dated 26.02.2020), wherein exemption has been held as rightly denied in view of the non- satisfaction of the conditions of r. 2BA. In the instant case

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Soundararajan K.

TDS from advertisement charge was seized in search warranting the disallowance and that without such a seizure no disallowance u/s 40(a)(ia) can be made in a search assessment as held by the Ho'ble High Court of Delhi in the case of Meeta Gutgutia (2017) (the SLP flied by the Revenue against this judgment was dismissed

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Soundararajan K.

TDS from advertisement charge was seized in search warranting the disallowance and that without such a seizure no disallowance u/s 40(a)(ia) can be made in a search assessment as held by the Ho'ble High Court of Delhi in the case of Meeta Gutgutia (2017) (the SLP flied by the Revenue against this judgment was dismissed