THE DCIT, KOCHI vs. M/S.SFO TECHNOLOGIES P. LTD, ALUVA

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

Section 14A r.w.Rule 8D and made disallowance of expenditure to the tune of Rs.1,83,55,106/- which stood added to the income of the assesse vide assessment order dated 26.03.2014 passed by AO u/s 143(3) of the 1961 Act for ay: 2010-11, the working of which is as hereunder: “4.3 Accordingly, the disallowance u/s 14A read with

THE DCIT, KOCHI vs. M/S.SFO TECHNOLOGIES P. LTD, ALUVA

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

Section 14A r.w.Rule 8D and made disallowance of expenditure to the tune of Rs.1,83,55,106/- which stood added to the income of the assesse vide assessment order dated 26.03.2014 passed by AO u/s 143(3) of the 1961 Act for ay: 2010-11, the working of which is as hereunder: “4.3 Accordingly, the disallowance u/s 14A read with

THE DCIT, KOCHI vs. M/S.SFO TECHNOLOGIES P. LTD, ALUVA

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

Section 14A r.w.Rule 8D and made disallowance of expenditure to the tune of Rs.1,83,55,106/- which stood added to the income of the assesse vide assessment order dated 26.03.2014 passed by AO u/s 143(3) of the 1961 Act for ay: 2010-11, the working of which is as hereunder: “4.3 Accordingly, the disallowance u/s 14A read with

THE DCIT, KOCHI vs. M/S.SFO TECHNOLOGIES P. LTD, ERNAKULAM

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

Section 14A r.w.Rule 8D and made disallowance of expenditure to the tune of Rs.1,83,55,106/- which stood added to the income of the assesse vide assessment order dated 26.03.2014 passed by AO u/s 143(3) of the 1961 Act for ay: 2010-11, the working of which is as hereunder: “4.3 Accordingly, the disallowance u/s 14A read with

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that, in fact, the assessee had written off the said amounts and hence there could be a deduction claimed under Section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that, in fact, the assessee had written off the said amounts and hence there could be a deduction claimed under Section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that, in fact, the assessee had written off the said amounts and hence there could be a deduction claimed under Section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that, in fact, the assessee had written off the said amounts and hence there could be a deduction claimed under Section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that, in fact, the assessee had written off the said amounts and hence there could be a deduction claimed under Section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that, in fact, the assessee had written off the said amounts and hence there could be a deduction claimed under Section

THEDCIT, COCHIN vs. M.S COCHIN INTERNATIONAL AIRPORT LTD, COCHIN

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

10. The Revenue’s third ground in AY 2011-12 appeal raises the issue of section 36(1)(va) disallowance

THE DCIT, COCHIN vs. M.S COCHIN INTERNATIONAL AIRPORT LTD, COCHIN

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

10. The Revenue’s third ground in AY 2011-12 appeal raises the issue of section 36(1)(va) disallowance

THE DCIT, COCHIN vs. M/S.COCHIN INTERNATIONAL AIRPORT LTD, COCHIN

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

10. The Revenue’s third ground in AY 2011-12 appeal raises the issue of section 36(1)(va) disallowance

THE DCIT, COCHIN vs. M/S.COCHIN INTERNATIONAL AIRPORT LTD, COCHIN

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

10. The Revenue’s third ground in AY 2011-12 appeal raises the issue of section 36(1)(va) disallowance

LAXMI MEGHAN EDUCATIONAL TRUST,KANHANGAD vs. ITO, EXEMPTION, KANNUR, KANNUR

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri George George K & Ms. Padmavathy Sassessment Year :2012-13 M/S. Laxmi Meghan Educational Trust, Ito (Exemptions), Vs. Kmc W1/1504, Surgicare Centre & Hospital, Kannur – 670 006. Kasargode District, Kerala. Pan :Aaatl8244M Assessee Respondent

sections 12AA and 10(23C) (vi). 3. The Id. CIT(A) has grievously erred in rejecting the prayer u/s. 10(23C) (iii ad) stating that " There are no documents on record to show that during the financial year under consideration, the assessee trust existed solely for educational propose and not for purposes of profit and that the aggregate

THE FEDERAL BANK LTD,ALUVA vs. THE ACIT, KOCHI

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” ITA Nos. 745 to 747/Coch/2019 ITA Nos. 33 to 35, 272 to 275, 309 to 311/Coch/2020 Page 6 of 28 The conclusion of the Hon’ble Court was therefore that prior

THE FEDERAL BANK LTD,ALUVA vs. THE ACIT, KOCHI

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” ITA Nos. 745 to 747/Coch/2019 ITA Nos. 33 to 35, 272 to 275, 309 to 311/Coch/2020 Page 6 of 28 The conclusion of the Hon’ble Court was therefore that prior

THE ACIT, KOCHI vs. THE FEDERAL BANK LTD, ERNAKULAM

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” ITA Nos. 745 to 747/Coch/2019 ITA Nos. 33 to 35, 272 to 275, 309 to 311/Coch/2020 Page 6 of 28 The conclusion of the Hon’ble Court was therefore that prior