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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

disallowance of the said expenditure under Section 40(a)(ia) of IT Act. 18. With a view to mitigate this hardship, Section 40(a)(ia) was amended by the Finance Act, 2008 and the provision so amended read as under:— "40. Notwithstanding anything to the contrary in Sections 30 to 38, the following amounts shall not be deducted in computing

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

30 of EPF&MP Act is also pointed out to argue that whether it be the contribution of the employer or the employee, it is the liability of the employer and, hence, the employer's and employee's contribution cannot be treated differently insofar as the deductions permissible under Section 36 (1) (va) 4. The Commissioner of Income Tax (Appeals

M/S THE REGIONAL AGRO INDUSTRIAL DEVELOPMENT COOPERATIVE OF KERALA LTD,KANNUR vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KANNUR RANGE

Bench: The Tribunal Within The Time Prescribed. Accordingly, The Delay Of 69 Days In Filing The Present Appeal Is Condoned.

30,560/- invoking Section 40A(3) of the Act. The aforesaid disallowance was confirmed by the Learned CIT(A) as the appeal preferred by the Assessee challenging the aforesaid disallowance was dismissed by the Learned CIT(A) vide Order, dated 24/03/2025, impugned by way of present appeal on the grounds reproduced in paragraph 2 above. 4. We have heard both

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

disallowance thereof would obtain for years prior to AY 2015-2016. 4. We have heard the parties, and perused the material on record. 4.1 Taking the first issue, the Revenue’s understanding of the amended s. 2(15) stands endorsed by the Apex Court in Ahmedabad Urban Development Authority 3 ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala

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

disallowance thereof would obtain for years prior to AY 2015-2016. 4. We have heard the parties, and perused the material on record. 4.1 Taking the first issue, the Revenue’s understanding of the amended s. 2(15) stands endorsed by the Apex Court in Ahmedabad Urban Development Authority 3 ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala

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

disallowance thereof would obtain for years prior to AY 2015-2016. 4. We have heard the parties, and perused the material on record. 4.1 Taking the first issue, the Revenue’s understanding of the amended s. 2(15) stands endorsed by the Apex Court in Ahmedabad Urban Development Authority 3 ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala

M/S.IBS SOFTWARE SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

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

10 Assessment Year 2013-2014 disallowance made by the Assessing Officer and submitted that loss on onerous contract was merely a provision for unascertained liability and therefore, deduction could not be allowed for the same. It was submitted that DRP has observed that the liability of the assessee did not arise during the relevant previous year as the settlement deeds

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

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

10% advances made by rural branches and 8.5% for other branches. The assessing officer without considering the submissions had mechanically disallowed the 30% of the interest payments for not deducting the 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

PALAKKAD SERVICE CO-OPERATIVE BANK LTD,PALAKKAD vs. ITO, PALAKKAD

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

disallowance of deduction claimed on the interest on the income tax refunds. We have considered the argument that the assessee had paid the extra income tax on Page 5 of 10 S.A. Nos. 4 & 5/Coch/2024 & ITA Nos. 30 & 31/Coch/2024 the business carried on by them and thereafter the revenue had refunded the amount while making the assessment for which

PALAKKAD SERVICE CO-OPERATIVE BANK LTD,PALAKKAD vs. ITO, PALAKKAD

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

disallowance of deduction claimed on the interest on the income tax refunds. We have considered the argument that the assessee had paid the extra income tax on Page 5 of 10 S.A. Nos. 4 & 5/Coch/2024 & ITA Nos. 30 & 31/Coch/2024 the business carried on by them and thereafter the revenue had refunded the amount while making the assessment for which

M/S.STATE BANK OF INDIA(SUCCESSOR TO STATE BANK OF TRAVANCORE),TRIVANDRUM vs. THE ACIT, TRIVANDRUM

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance /addition amounting to Rs.10,90,20,000/- made in the course of assessment herein dated 16.12.2015 as upheld in the CIT(A)'s detailed discussion as under : “2.3. I considered both the views expressed. As per section 36(1)(vili) of the Act, what is to be considered is the profit derived from the eligible business computed under

M/S.STATE BANK OF INDIA(SUCCESSOR TO STATE BANK OF TRAVANCORE),TRIVANDRUM vs. THE ACIT, TRIVANDRUM

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance /addition amounting to Rs.10,90,20,000/- made in the course of assessment herein dated 16.12.2015 as upheld in the CIT(A)'s detailed discussion as under : “2.3. I considered both the views expressed. As per section 36(1)(vili) of the Act, what is to be considered is the profit derived from the eligible business computed under