AYUR GREEN AYURVEDA HOSPITALS PRIVATE LIMITED,MALAPPURAM vs. DCIT, CPC, BENGALURU, BENGALURU

In the result, the assessee’s appeal is dismissed

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmiayurgreen Ayurveda Hospsitals Vs Dcit, Private Limited Cpc, Door No. 1/301 Ayurgreen Bengaluru. Ayurveda Hospitals, Kaladi Mlp Edappal, Malappuram-679585. (Appellant) (Respondent) Pan No. Aaica 4294 M

2. As per the Office record, Service is complete on the sole respondent but none has entered appearance on behalf of the Respondnet Assessee. 3. Mr. Balbir Sharma, learned Additional Solicitor General appearing for the appellant submits that the issue involved in this appeal is squarely answered in favour of the Revenue by a Three-Judge Bench of this Court

PLANT LIPIDS (P) LTD.,KADAYIRUPPU vs. DCIT , CORPORATE CIRCLE-2(1), KOCHI

In the result appeal filed by assessee stands allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessmentyear:2020-21 Plant Lipids (P) Ltd. Kadayiruppu Po Kolenchery Dcit, Vs. Kerala 682 311 Corporate Circle-2(1) Kochi Pan No : Aabcp6061C Appellant Respondent Appellant By : Shri Thomson Thomas, A.R. Respondent By : Shri Sanjit Kumar Das, D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 O R D E R Perkeshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ao, Assessment Unit, Income Tax Department Dated 19.6.2024 Vide Din No.Itba/Ast/S/143(3)/2024- 25/1065876641(1) For The Ay 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”). 2. The Assessee Has Raised Following Grounds Of Appeal: Plant Lipids (P) Ltd., Kolencherry, Kerala Page 2 Of 8

11. This amendment will take effect from 1/04/2015 and will, accordingly, apply to assessment year 2015-16 and subsequent years. 12. Thus, CSR expenditure is to be disallowed by new Explanation 2 to section 37(1), while computing Incomeunder the Head ‘Income form Business and Profession’. Further, clarification regarding impact of Explanation 2 to section 37(1) of the Income

INFOPARKS KERALA,COCHIN vs. THE ACIT, COCHIN

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

section 2(15), i.e., by Finance Act, 2010 w.r.e.f. 01.4.2009, which reads asunder: ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala v. Jt.DIT "Definitions 2. In this Act, unless context otherwise requires,– (15) “Charitable purpose” includes relief of the poor, education, medical relief, and the advancement of any other object of general public utility: Provided that the advancement

INFOPARKS KERALA,TRIVANDRUM vs. THE JT DIRECTOR OF IT (OSD) EXEM), COCHIN

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

section 2(15), i.e., by Finance Act, 2010 w.r.e.f. 01.4.2009, which reads asunder: ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala v. Jt.DIT "Definitions 2. In this Act, unless context otherwise requires,– (15) “Charitable purpose” includes relief of the poor, education, medical relief, and the advancement of any other object of general public utility: Provided that the advancement

INFOPARKS KERALA,TRIVANDRUM vs. THE JT DIRECTOR OF IT (OSD) EXEM), COCHIN

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

section 2(15), i.e., by Finance Act, 2010 w.r.e.f. 01.4.2009, which reads asunder: ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala v. Jt.DIT "Definitions 2. In this Act, unless context otherwise requires,– (15) “Charitable purpose” includes relief of the poor, education, medical relief, and the advancement of any other object of general public utility: Provided that the advancement

THE NEHRU MEMORIAL EDUCATION SOCIETY,KANHANGAD vs. ITO EXEMPTIONS, KANNUR

In the result, the assessee’s appeal is allowed

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmithe Nehru Memorial The Income Tax Officer Education Society (Exemptions), Kannur Lakshmi Nivas Vs. Kanhangad - 671315 Kasaragod [Pan:Aabtt0633M] (Appellant) (Respondent)

11(1)(a), (b) or (d) (s. 12A(1)(aa) (also see: U.P. Forest Corporation v. Dy. CIT [2008] 297 ITR 1 (SC)). Further, the application for registration having been made by the assessee-society on 18.02.2015, it’s registration on 20.08.2015, w.e.f. AY 2015-16, is opposite [s.12AA(2)]. The question here would be if the contribution

THE DHARMODAYAM COMPANY,THRISSUR vs. ITO, WARD-1(1), THRISSUR

In the result, the appeals in ITA No

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

section 25 of the Companies Act. The company was duly registered u/s. 12A of the Act. The return of income for AY 2009-10 was filed on10.09.2009 declaring Nil income after claiming exemption u/s. 11 of the Income Tax Act, 1961 (the Act). Against the said return of income, the assessment was completed by the ITO, Ward -1(1), Thrissur

THE DHARMODAYAM COMPAN,THRISSUR vs. ITO, WARD-1(1), THRISSUR

In the result, the appeals in ITA No

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

section 25 of the Companies Act. The company was duly registered u/s. 12A of the Act. The return of income for AY 2009-10 was filed on10.09.2009 declaring Nil income after claiming exemption u/s. 11 of the Income Tax Act, 1961 (the Act). Against the said return of income, the assessment was completed by the ITO, Ward -1(1), Thrissur

THE DHARMODAYAM COMPANY,THRISSUR vs. ITO, WARD-1(1), THRISSUR

In the result, the appeals in ITA No

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

section 25 of the Companies Act. The company was duly registered u/s. 12A of the Act. The return of income for AY 2009-10 was filed on10.09.2009 declaring Nil income after claiming exemption u/s. 11 of the Income Tax Act, 1961 (the Act). Against the said return of income, the assessment was completed by the ITO, Ward -1(1), Thrissur

THE DHARMODAYAM COMPANY,THRISSUR vs. ITO, WARD-1(1), THRISSUR

In the result, the appeals in ITA No

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

section 25 of the Companies Act. The company was duly registered u/s. 12A of the Act. The return of income for AY 2009-10 was filed on10.09.2009 declaring Nil income after claiming exemption u/s. 11 of the Income Tax Act, 1961 (the Act). Against the said return of income, the assessment was completed by the ITO, Ward -1(1), Thrissur

THRISSUR DISTRICT POLICE CO OPERATIVE SOCIETY LTD,THRISSUR vs. INCOME TAX OFFICER, THRISSUR

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

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

section 250 of the act, the ld. CIT(A)/NFAC has wrongly mentioned the addition figure as ₹ 1, 61,41,520/- as against the actual figure of ₹ 53,85,753/- 9. The ld. DR on the other hand relied upon the order of the ld. CIT (A)/NFAC. 10. On going through the orders of the AO as well

THRISSUR DISTRICT POLICE CO OPERATIVE SOCIETY LTD,THRISSUR vs. INCOME TAX OFFICER, THRISSUR

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

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

section 250 of the act, the ld. CIT(A)/NFAC has wrongly mentioned the addition figure as ₹ 1, 61,41,520/- as against the actual figure of ₹ 53,85,753/- 9. The ld. DR on the other hand relied upon the order of the ld. CIT (A)/NFAC. 10. On going through the orders of the AO as well

THE ACIT, COCHIN vs. M/S.PVR TOURIST HOME, COCHIN

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Year: 2012-13 Acit, Circle-1, Non-Corporate .......... Appellant Iind Floor, C.R. Building, I.S. Press Road Ernakulam 682018 Vs. Pvr Tourist Home .......... Respondent Palarivattom, Kochi 682025 [Pan: Aadfp3442Q] Appellant By: Shri Suresh Sivanandan, Cit-Dr Respondent By: Shri Mohan Pulickal, Advocate Date Of Hearing: 10.03.2025 Date Of Pronouncement: 21.03.2025

11. On the other hand, the learned A.R. of the assessee submits that for the purpose of computing capital gains as per section 45(4) of the Act the computation is to be done in the manner prescribed u/s. 48 r.w.s. 50 of the Act. He further submits that for the purpose computing capital gain

POLAKULATH NARAYANAN RENAI MEDICITY,KOCHI vs. THE DCIT NON CORP CIRCLE 1(1), KOCHI

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

Bench: Shri Chandra Poojari & Shri Soundararajan K.Polakulath Narayanan Renai Dcit, Non Corporate Circle 1(1) Medicity C.R. Building, I.S. Press Road Main Road, Palarivattom Vs. Kochi 682018 Kochi 682025 Pan – Aaifp7597B (Appellant) (Respondent) Assessee By: Shri Mathew Joseph, Ca Revenue By: Ms. Swarnalatha, Sr.Dr Date Of Hearing: 10.07.2024 Date Of Pronouncement: 05.08.2024 O R D E R Per: Soundararajan K.,J.M. This Appeal Filed By The Assessee Challenges The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 23.04.2023 In Respect Of Assessment Year (Ay) 2014-15. 2. The Brief Facts Of The Case Are That The Assessee Is Running A Hospital & During The Assessment Year The Assessing Authority Had Capitalised The Interest Component Of The Interior Works For The Reason That The Work Was Done Over A Period Of Time & Hence The Interest Till The Completion Of The Work Is To Be Capitalised. The Assessing Officer (Ao) Also Capitalised The Interest Component On The Capital Asset I.E.On The Sewage Plant Since The Same Was Put Into Use At The Fag End Of The Assessment Year. The Ao Also Treated The Interest On Fixed Deposits As Margin Money Under The Head ‘Income From Other

depreciation determined in the scrutiny assessment order passed on 04/03/2016 for the A.Y 2013-14 amounting to Rs. 18,92,878/- was not set off u/s 32(2) while levying tax of Rs.4,05,940/- on Rs. 11,07,430/-, According to section

THE DCIT, CIRCLE-2(1), THRISSUR vs. SRI.K.P. JOHNY, THRISSUR

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Dask.P. Johny Asst. Cit, Manappuram House Circle – 2(1) Hospital Road, Chalakkudy Aayakar Bhavan Vs. Thrissur 680307 Sakthan Thampuran Nagar [Pan:Acgpj4958G] Thrissur 680001 (Appellant) (Respondent) Asst. Cit, K.P. Johny Circle – 2(1) Manappuram House Aayakar Bhavan Hospital Road, Chalakkudy Vs. Sakthan Thampuran Nagar Thrissur 680307 Thrissur 680001 [Pan: Acgpj4958G] (Appellant) (Respondent)

section 133A of the Act at the business premises of one, Shri Ittoop Konuparamban, Chalakkudy, Thrissur, also the place of the assessee’s residence, on 13.03.2015, on the basis of the material impounded there-from and the subsequent statement of Shri Ittoop and, indeed, the assessee himself. The assessee, who had not filed any return of income for the year

SRI.K.P. JOHNY,THRISSUR vs. THE DCIT, CIRCLE-2(1), THRISSUR

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Dask.P. Johny Asst. Cit, Manappuram House Circle – 2(1) Hospital Road, Chalakkudy Aayakar Bhavan Vs. Thrissur 680307 Sakthan Thampuran Nagar [Pan:Acgpj4958G] Thrissur 680001 (Appellant) (Respondent) Asst. Cit, K.P. Johny Circle – 2(1) Manappuram House Aayakar Bhavan Hospital Road, Chalakkudy Vs. Sakthan Thampuran Nagar Thrissur 680307 Thrissur 680001 [Pan: Acgpj4958G] (Appellant) (Respondent)

section 133A of the Act at the business premises of one, Shri Ittoop Konuparamban, Chalakkudy, Thrissur, also the place of the assessee’s residence, on 13.03.2015, on the basis of the material impounded there-from and the subsequent statement of Shri Ittoop and, indeed, the assessee himself. The assessee, who had not filed any return of income for the year

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

11 Receipt of corporate marketing services 391,40,800 12 Provision of corporate purchase 23,08,219 services 13 Provision of corporate information 2,32,10,5456 technology services 14 Investment in equity 50,02,98,250 15 Reimbursement of expenses 1,07,78,001 16 Recovery of expenses 3,69,14,146 3. On noticing the above international transactions

CARMEL CONVENT ,THIRUVANANTHAPURAM vs. ITO EXEMPTION WARD, TRIVANDRAM, THIRUVANANTHAPURAM

In the result, the assessee’s appeal is partly allowed and partly allowed for statistical purposes, and it’s stay petition is dismissed

Bench: Shri Sanjay Arora & Dr. Seethalakshmi

2 Carmel Convent v. Income Tax Officer (Exemption) development charges, library fees, computer fees, etc. and the parents do not have any choice to deny any of these fees/charges. In fact, the appellant did not furnish any information / document to show that school development fund and welfare fund was not collected from each & every child due to voluntary nature

KUMAR MADHAVANPILLAI.S,THIRUVANANTHAPURAM vs. ITO, WARD-1(4), TRIVANDRUM

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Kumar Madhavanpillai S. Income Tax Officer -1(4) Chandra Press & Book Depot Aayakar Bhavan, Kowdiar P.O. Manjalikulam Road Thiruvananthapuram 695003 Vs. Thampanoor Thiruvananthapuram 695001 [Pan: Ajxps9299P] (Appellant) (Respondent)

2),(3), (4) & (5) for a consideration of Rs. 1.75 crore which includes land value at Rs. 1.25 crore and building value of Rs. 50 Lakh. Thereafter the AO found, as per the municipal property tax receipt, out of 4 TC number only property being TC No. 25/1684/(4)was residential property and remaining were commercial properties. The AO also