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43 results for “disallowance”+ Revision u/s 263clear

Sorted by relevance

Mumbai1,460Delhi793Kolkata619Chennai459Bangalore429Ahmedabad235Pune163Jaipur161Hyderabad131Chandigarh125Indore113Rajkot113Surat104Raipur62Visakhapatnam46Panaji43Cochin43Cuttack37Nagpur36Lucknow34Karnataka27Agra25Allahabad21Jodhpur21Amritsar19Patna11Jabalpur8Dehradun7Telangana4Kerala3Guwahati3Ranchi3Calcutta2Varanasi2SC1Rajasthan1Punjab & Haryana1

Key Topics

Section 263126Section 143(3)50Disallowance23Revision u/s 26322Section 80P(2)(a)18Section 2(15)18Addition to Income18Deduction16Section 115B15Depreciation

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

ITA 389/COCH/2020[2015-16]Status: DisposedITAT Cochin01 Aug 2022AY 2015-16

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

For Appellant: Shri K. Gopi, CAFor Respondent: Shri Shantam Bose, CIT DR
Section 143Section 143(3)Section 263Section 42

revision u/s 263 of the Income Tax Act. It is submitted that the assessments completed legally and in accordance with law cannot be re-opened u/s 263 based on the 3 M/s. Kerala State Warehousing Corporation judicial review of a supervisory authority. The appellant submits that there is no error, which is prejudicial to the revenue, in respect

Showing 1–20 of 43 · Page 1 of 3

15
Section 1113
Exemption12

DHNALAXMI BANK LIMITED,TRICHUR vs. THE PR CIT, THRISSUR

Appeal is allowed

ITA 56/COCH/2021[2016-17]Status: DisposedITAT Cochin19 Dec 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.Assessment Year : 2016-17

For Appellant: Shri Harikrishnanunny, CAFor Respondent: Smt. M. Rajasekhar, CIT(DR)
Section 10(33)Section 14Section 143Section 143(2)Section 14ASection 263

revising the assessment u/s 263 of the Act, as the assessment made under section 143 (3) of the Income Tax Act, 1961 (the Act) for the year is neither erroneous nor prejudicial to the interests of the revenue. 3. The learned PCIT erred in making the disallowance

INCOME TAX OFFICER (EXEMPTIONS), KOTTAYAM, KOTTAYAM vs. MALANADU MILK PRODUCERS SOCIETY, KANJIRAPALLY, KOTTAYAM

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

ITA 633/COCH/2024[2017-18]Status: DisposedITAT Cochin11 Mar 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Shyju Joseph, CA
Section 11Section 12ASection 142(1)Section 143(3)Section 2(15)Section 263

revision order passed u/s. 263 of the Act by the Ld.CIT(E) and therefore the consequential order passed by the assessment unit is also an illegal order and therefore the Ld.CIT(A) had rightly allowed the appeal filed by the assessee. The Ld.AR further submitted that the mere pendency of appeal would not be a ground to attack the order

KADUNGALLOOR SERVICE CO-OPERATIVE BANK LTD. NO.2165,KARUMALOOR vs. INCOME TAX OFFICER, ALUVA

In the result, the appeals of the assessee stand dismissed

ITA 346/COCH/2025[2020-21]Status: DisposedITAT Cochin15 Jul 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)

disallowance of claim for deduction u/s. 80P(2)(a)(i) of the Act. While the matter stood thus, the ld. Pr. CIT found that the assessment order passed by the AO is erroneous and prejudicial Kadungalloor Service Co-op. Bank Ltd. to the interests of Revenue, as the AO failed to verify the issue of taxability of reserves/provisions debited

KADUNGALLOOR SERVICE CO-OPERATIVE BANK LTD.NO.2165,KARUMALOOR vs. INCOME TAX OFFICER, ALUVA

In the result, the appeals of the assessee stand dismissed

ITA 348/COCH/2025[2022-23]Status: DisposedITAT Cochin15 Jul 2025AY 2022-23

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)

disallowance of claim for deduction u/s. 80P(2)(a)(i) of the Act. While the matter stood thus, the ld. Pr. CIT found that the assessment order passed by the AO is erroneous and prejudicial Kadungalloor Service Co-op. Bank Ltd. to the interests of Revenue, as the AO failed to verify the issue of taxability of reserves/provisions debited

KADUNGALLOOR SERVICE CO-OPERATIVE BANK LTD.NO.863,ALUVA vs. INCOME TAX OFFICER, ALUVA

In the result, the appeals of the assessee stand dismissed

ITA 347/COCH/2025[2021-22]Status: DisposedITAT Cochin15 Jul 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)

disallowance of claim for deduction u/s. 80P(2)(a)(i) of the Act. While the matter stood thus, the ld. Pr. CIT found that the assessment order passed by the AO is erroneous and prejudicial Kadungalloor Service Co-op. Bank Ltd. to the interests of Revenue, as the AO failed to verify the issue of taxability of reserves/provisions debited

M/S.ROADS AND BRIDGES DEVELOPMENT CORPN OF KERALA LTD,ERNAKULAM vs. THE ACIT, KOCHI

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

ITA 33/COCH/2021[2016-17]Status: DisposedITAT Cochin20 Jan 2023AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2016-17

For Appellant: Ms. Remya S Menon, CAFor Respondent: Smt. J M Jamuna Devi, Sr DR
Section 139(1)Section 139(3)Section 143(3)Section 263Section 32(2)Section 72(1)

disallowed by the AO against which the company is in appeal before the CIT(A) and therefore the subject matter of appeal is the same as the matter raised in proceedings u/s. 263 which is barred as per clause (c) of Explanation(1) of section 263. The Ld.DR relied on the order of the PCIT. 8. We have heard

M/S.ARMAJARO TRADING INDIA P. LTD,ERNAKULAM vs. THE ITO, KOCHI

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

ITA 10/COCH/2021[2016-17]Status: DisposedITAT Cochin18 May 2022AY 2016-17

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am

For Appellant: Sri.Mohit Ashok Parmar, CAFor Respondent: Sri.Shantham Bose, CIT-DR
Section 143(3)Section 263

revision under section 263 cannot be made to substitute the views of the AO. 8. Without prejudice, the learned Pr. CIT has erred in not appreciating the fact that the share application money was received during the FY 2013-14 and FY 2014-15 from its holding company Armajaro Trading limited, UK (also known as Ecom Agrotrade Limited

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. DCIT, CIRCLE 1(1)&TPS, THRISSUR

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

ITA 287/COCH/2024[2017-2018]Status: DisposedITAT Cochin04 Aug 2025AY 2017-2018

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2017-18 The South Indian Bank Ltd., .......... Appellant Head Office, Mission Quarters, T.B. Road, Thrissur. [Pan: Aabct 0022 F] Vs. Dy. Commissioner Of Income Tax .......... Respondent Circle-1(1) & Tps, Thrissur Appellant By: Shri Naresh C, Ca Respondent By: Smt. Veni Raj, Cit-Dr Date Of Hearing: 12.06.2025 Date Of Pronouncement: 04.08.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 07.02.2024 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Private Scheduled Bank, Engaged In The Business Of Banking. The Return Of Income For The A.Y. 2017-18 Was Filed On 31/03/2018 Declaring Income Of Rs. 446,81,29,140/-. Against The Said Return Of Income, The Assessment Was Completed By The Dcit, Circle-1(1) & Tps

For Appellant: Shri Naresh C, CAFor Respondent: Smt. Veni Raj, CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(viii)Section 36(1)(viiia)

disallowed the bad debts written off and also the provisional bad debts of Rs. 52 crores which cannot be allowed in 3 The South Indian Bank Ltd. the assessment made pursuant to the revisionary order passed by the learned PCIT. 4. Being aggrieved, the assessee is in appeal before this tribunal in the present appeal. 5. We have heard

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

In the result, both the appeals of the assessee are allowed

ITA 268/COCH/2023[2005-06]Status: DisposedITAT Cochin03 Jan 2025AY 2005-06

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Radhesh Bhatt, CAFor Respondent: Shri Sanjit Kumar Das, CIT(DR)
Section 143(2)Section 143(3)Section 250Section 263Section 32Section 32(1)Section 47

revised by the CIT-II, Kochi by order u/s. 263 of the Act dated 03.3.2011 setting aside assessment already passed u/s. 143(3) r.w.s. 147 dated 26.12.2008 for redoing the same. Subsequently notices were issued u/s. 143(2) on 27.11.2011. 4. During the assessment proceedings it was found that assessee firm over the years had developed a software called ‘Quadra

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

In the result, both the appeals of the assessee are allowed

ITA 269/COCH/2023[2005-06]Status: DisposedITAT Cochin03 Jan 2025AY 2005-06

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Radhesh Bhatt, CAFor Respondent: Shri Sanjit Kumar Das, CIT(DR)
Section 143(2)Section 143(3)Section 250Section 263Section 32Section 32(1)Section 47

revised by the CIT-II, Kochi by order u/s. 263 of the Act dated 03.3.2011 setting aside assessment already passed u/s. 143(3) r.w.s. 147 dated 26.12.2008 for redoing the same. Subsequently notices were issued u/s. 143(2) on 27.11.2011. 4. During the assessment proceedings it was found that assessee firm over the years had developed a software called ‘Quadra

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. PCIT, , THRISSUR

In the result, the appeal by the assessee is allowed

ITA 628/COCH/2024[2018-19]Status: DisposedITAT Cochin27 May 2025AY 2018-19

Bench: Shri Inturi Rama Raoshri Sandeep Singh Karhailthe South Indian Bank Limited, Head Office, Mission Quarters, Tb Road, Thrissur Kerala - 680001 ............... Appellant Pan : Aabct0022F V/S Pcit, Aayakar Bhavan, North Block, ……………… Respondent New Annex Building Mananchira, Kozhikode Kerala.

For Appellant: Shri Naresh C, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 142(1)Section 143Section 143(2)Section 143(3)Section 154Section 250Section 263Section 36(1)(vii)Section 36(1)(viia)Section 36(2)(v)

u/s 36(1)(vii) for the Assessment year 2017-18 showed only a debit balance in the provision for bad and doubtful accounts there is no question of disallowing any deduction and hence even on merits revision of order of AO dated 17-02-2021 is not called for.” 3. The solitary grievance of the assessee, in the present appeal

SOUTH MALABAR GRAMIN BANK,MALAPPURAM vs. THE ACIT, CIRCLE-1, TIRUR, TIRUR

Appeal is allowed for statistical purposes

ITA 788/COCH/2022[2011-2012]Status: DisposedITAT Cochin08 Mar 2023AY 2011-2012

Bench: Shri George George K. & Ms. Padmavathy S.Assessment Year : 2011-12

For Appellant: Shri Deepak Jose, CAFor Respondent: Smt. J M Jamuna Devi, Sr. AR
Section 143(2)Section 143(3)Section 263Section 36(1)(viia)Section 36(2)

revised u/s. 263 directing the AO to conduct a proper Page 2 of 4 verification and pass the order accordingly. The AO completed the assessment u/s. 143(3) r.w.s. 263 by making a further disallowance

CSB BANK LTD.,THRISSUR vs. DCIT CIRCLE 1(1) & TPS THRISSUR, THRISSUR

In the result, both the appeals of the assessee are dismissed

ITA 563/COCH/2022[2017-2018]Status: DisposedITAT Cochin14 Sept 2022AY 2017-2018

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

For Appellant: Shri C. Naresh, A.RFor Respondent: Shri Shantam Bose, D.R
Section 143(3)Section 14ASection 263Section 438Section 43B

disallowed after due verification of amount involved in it. 2) To ascertain the tax liability in respect of provision for frauds after verifying the facts that the amount stated against provision towards NPA/Write off amounting to Rs.217.89 crores includes provision for fraud amounting to Rs.3,00,57,799/-. ITA Nos.84/Coch/2021 & CSB Bank Ltd., Thrissur Page 6 of 15 2.6 Regarding

CSB BANK LTD ( FORMERLY THE CATHOLIC SRIAN BANK LTD,THRISSUR vs. THE PR CIT, KOZHIKKODE

In the result, both the appeals of the assessee are dismissed

ITA 84/COCH/2021[2016-17]Status: DisposedITAT Cochin14 Sept 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

For Appellant: Shri C. Naresh, A.RFor Respondent: Shri Shantam Bose, D.R
Section 143(3)Section 14ASection 263Section 438Section 43B

disallowed after due verification of amount involved in it. 2) To ascertain the tax liability in respect of provision for frauds after verifying the facts that the amount stated against provision towards NPA/Write off amounting to Rs.217.89 crores includes provision for fraud amounting to Rs.3,00,57,799/-. ITA Nos.84/Coch/2021 & CSB Bank Ltd., Thrissur Page 6 of 15 2.6 Regarding

LAKESHORE HOSPITAL AND RESEARCH CENTRE LIMITED,KOCHI vs. ACIT, CORPORATE CIRCLE 1(2), KOCHI

In the result, the assessee’s appeal is dismissed

ITA 70/COCH/2023[2010-11]Status: DisposedITAT Cochin11 Dec 2023AY 2010-11

Bench: Shri Sanjay Arora & Shri Manomohan Daslakeshore Hospital & Rsearch Asst. Cit, Centre Ltd. Corporatecircle 1(1), Xvi Maradu, Nh 47 Bye Pass Vs. C.R. Building, Is Press Road Netoor P.O., Kochi 682040 Kochi 682018 [Pan:Aaacl4923A] (Appellant) (Respondent)

For Appellant: Ms. Rohini V. Thampi, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)Section 263Section 263(1)Section 36(1)(vii)

revision order, read out during hearing, reading as under: “6.4 It may also not be out of place to mention here that the order of the AO against which the instant appeal has been filed is merely an order giving effect to the clear cut decision of the CIT in his order u/s. 263 directing the AO to disallow

MALANADU MILK PRODUCERS SOCIETY,KOTTAYAM vs. DCIT, EXEMPTION, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

ITA 633/COCH/2022[2017-2018]Status: DisposedITAT Cochin08 Mar 2023AY 2017-2018

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Jose Kappan, CAFor Respondent: Shri Prashant V.K., CIT(DR)
Section 11Section 12ASection 143(1)Section 143(2)Section 2(15)Section 263

disallowed. ITA NoS.632 & 633/Coch/2022 Page 3 of 12 4. In such circumstances, you are requested to explain why the assessment order passed u/s 143(1) of the Act in your case on 11/10/2019 shall not be treated as erroneous and be revised accordingly.” 4. The assessee filed a detailed reply dated 2.3.2022 (pg. 45 to 51 of PB) where

MALANADU FARMERS SOCIETY ,KOTTAYAM vs. DCIT EXEMPTIONS, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

ITA 632/COCH/2022[2017-2018]Status: DisposedITAT Cochin08 Mar 2023AY 2017-2018

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Jose Kappan, CAFor Respondent: Shri Prashant V.K., CIT(DR)
Section 11Section 12ASection 143(1)Section 143(2)Section 2(15)Section 263

disallowed. ITA NoS.632 & 633/Coch/2022 Page 3 of 12 4. In such circumstances, you are requested to explain why the assessment order passed u/s 143(1) of the Act in your case on 11/10/2019 shall not be treated as erroneous and be revised accordingly.” 4. The assessee filed a detailed reply dated 2.3.2022 (pg. 45 to 51 of PB) where

MALLELIL INDUSTRIES PRIVATE LIMITED,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, THIRUVALLA

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

ITA 787/COCH/2024[2015-16]Status: DisposedITAT Cochin31 Jul 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2015-16 Mallelil Industries Pvt. Ltd. .......... Appellant Attachakkal P.O., Pathanamthitta 689691 [Pan: Aafcm0761Q] Vs. Acit, Circle-1, Thiruvalla .......... Respondent Appellant By: Shri Surendran, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 05.06.2025 Date Of Pronouncement: 31.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 24.08.2022 For Assessment Year (Ay) 2015-16. 2. Brief Facts Of The Case Are That The Appellant Is A Company Incorporated Under The Provisions Of Companies Act, 1956. It Is Engaged In The Business Of Manufacture Of Rock Aggregates & Running A Quarry. The Return Of Income For Ay 2015-16 Was Fled On 22.09.2015 Declaring Income Of Rs. 2,54,10,720/-. Survey

For Appellant: Shri Surendran, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 133ASection 263Section 271(1)(c)

263 is on account of disallowance of excess depreciation of Rs. 11,80,715/-. The AO also initiated penalty proceedings u/s. 271(1)(c) of the Act for concealment of income in the remand proceedings, since the return of income was revised

BHARAT CHARITABLE HOSPITAL SOCIETY ,KOTTAYAM vs. CIT (EXEMPTION), KOCHI AT TVM, KOCHI

In the result, the appeal filed by assessee is disposed of on the afore-said terms

ITA 649/COCH/2022[2017-20108]Status: DisposedITAT Cochin28 Aug 2023

Bench: Shri Sanjay Arora (Accountant Member), Shri Manomohan Das (Judicial Member)

For Appellant: K. Krishna K., AdvFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 11Section 12Section 12ASection 13(1)(c)Section 143(3)Section 263

disallowance. The assessee appealed there- against before the first appellate authority under the Act on 18/01/2020. It was subsequently show caused u/s. 263 of the Act. The ld. Pr. CIT was of the view that the AO had gone wrong in making the addition for Rs. 29.91 lacs. Once section 13(1)(c), reproduced hereunder in its relevant part