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212 results for “disallowance”+ Section 10(6)(vii)clear

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Key Topics

Section 25095Section 80P76Section 143(3)53Deduction45Section 5644Disallowance37Section 80P(2)25Addition to Income25Section 4019Section 2

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

ITA 399/COCH/2023[2017-18]Status: DisposedITAT Cochin13 Aug 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

6. The assessee’s third substantive ground challenge correctness of the lower authorities action in making sec.36(1)(viii) disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction

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

ITA 397/COCH/2023[2015-16]Status: DisposedITAT Cochin13 Aug 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

6. The assessee’s third substantive ground challenge correctness of the lower authorities action in making sec.36(1)(viii) disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction

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

ITA 394/COCH/2023[2012-13]Status: DisposedITAT Cochin13 Aug 2024AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

6. The assessee’s third substantive ground challenge correctness of the lower authorities action in making sec.36(1)(viii) disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction

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

ITA 393/COCH/2023[2011-12]Status: DisposedITAT Cochin13 Aug 2024AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

6. The assessee’s third substantive ground challenge correctness of the lower authorities action in making sec.36(1)(viii) disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction

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

ITA 396/COCH/2023[2014-15]Status: DisposedITAT Cochin13 Aug 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

6. The assessee’s third substantive ground challenge correctness of the lower authorities action in making sec.36(1)(viii) disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction

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

ITA 395/COCH/2023[2013-14]Status: DisposedITAT Cochin13 Aug 2024AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

6. The assessee’s third substantive ground challenge correctness of the lower authorities action in making sec.36(1)(viii) disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction

SRI.KRISHNAN ACHARY,PATHANAMTHITTA vs. THE ITO, WD-3,, THIRUVALLA

In the result, the appeal of the assessee is dismissed

ITA 432/COCH/2018[2008-09]Status: DisposedITAT Cochin24 Feb 2020AY 2008-09

Bench: Shri George George K.

Section 10Section 148

disallowing the claim of deduction u/s. 10(10C) of the I.T. Act. 4. The brief facts of the case are as follows: The assessee is an individual. For the assessment year 2008-09, the return of income was filed on 29/07/2008 declaring total income of Rs.3,03,310/-. During the previous year relevant to the assessment year

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

6. Against the above order of the Assessing Officer, the Draft Resolution Panel (DRP) has given a direction that USTIPL is rendering managerial, technical and consultancy services to the assessee by providing services of technical or other personnel. Thus the services come within purview of section 9(1)(vii) explanation 2 and provisions of section 194J are attracted in this

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

6. Against the above order of the Assessing Officer, the Draft Resolution Panel (DRP) has given a direction that USTIPL is rendering managerial, technical and consultancy services to the assessee by providing services of technical or other personnel. Thus the services come within purview of section 9(1)(vii) explanation 2 and provisions of section 194J are attracted in this

DY.COMMISSIONER OF INCOME TAX, THRISSUR vs. THE CSB BANK LTD, THRISSUR

In the result, the appeal of revenue is dismissed

ITA 542/COCH/2025[2014-15]Status: DisposedITAT Cochin30 Oct 2025AY 2014-15

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

For Appellant: Shri Satish Modi, CAFor Respondent: Shri. Sanjit Kumar Das, CIT DR
Section 115Section 115JSection 144BSection 147Section 250

disallowance of provisions of bad and doubtful debts to the extent of Rs. 57.57 crores is deleted. 3. The CIT(A) has erred on the following points while deleting the Book profit enhancement consequent to bad and doubtful debt the extent of Rs. 57.57 crores. 3.1. Vijaya Bank decision is applicable only for normal Income and not MAT Income [Minimum

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

ITA 167/COCH/2017[2011-12]Status: DisposedITAT Cochin23 Oct 2024AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

6 substantive grounds; assessment year-wise, respectively seeks to treat the interest on passenger service fee deposit as assessee’s taxable income in the corresponding assessment years. We do not see any material in the case which could indicate that the impugned interest income have been accrued or received in assessee’s book so as to treated as taxable

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

ITA 166/COCH/2017[2010-11]Status: DisposedITAT Cochin23 Oct 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

6 substantive grounds; assessment year-wise, respectively seeks to treat the interest on passenger service fee deposit as assessee’s taxable income in the corresponding assessment years. We do not see any material in the case which could indicate that the impugned interest income have been accrued or received in assessee’s book so as to treated as taxable

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

ITA 304/COCH/2017[2007-08]Status: DisposedITAT Cochin23 Oct 2024AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

6 substantive grounds; assessment year-wise, respectively seeks to treat the interest on passenger service fee deposit as assessee’s taxable income in the corresponding assessment years. We do not see any material in the case which could indicate that the impugned interest income have been accrued or received in assessee’s book so as to treated as taxable

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

ITA 193/COCH/2017[2012-13]Status: DisposedITAT Cochin23 Oct 2024AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

6 substantive grounds; assessment year-wise, respectively seeks to treat the interest on passenger service fee deposit as assessee’s taxable income in the corresponding assessment years. We do not see any material in the case which could indicate that the impugned interest income have been accrued or received in assessee’s book so as to treated as taxable

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

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

ITA 272/COCH/2020[2011-12]Status: DisposedITAT Cochin12 Dec 2022AY 2011-12

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

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin
Section 147Section 14ASection 154

6. Ground No. 2 relates to disallowance conformed by Ld. CIT (A) under rule 8D (iii) of Income Tax Rules, 1963. 6.1. At the outset, Ld.Counsel submitted that, this issue stands squarely covered by following observation by Hon’ble Supreme Court in case of Maxopp Investments vs CIT reported in (2018) 91 taxman.com 154, in favour of assessee: “36. There

ACIT, KOCHI vs. FEDERAL BANK LTD, ALUVA

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

ITA 35/COCH/2020[2010-11]Status: DisposedITAT Cochin12 Dec 2022AY 2010-11

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

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin
Section 147Section 14ASection 154

6. Ground No. 2 relates to disallowance conformed by Ld. CIT (A) under rule 8D (iii) of Income Tax Rules, 1963. 6.1. At the outset, Ld.Counsel submitted that, this issue stands squarely covered by following observation by Hon’ble Supreme Court in case of Maxopp Investments vs CIT reported in (2018) 91 taxman.com 154, in favour of assessee: “36. There

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

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

ITA 310/COCH/2020[2008-09]Status: DisposedITAT Cochin12 Dec 2022AY 2008-09

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

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin
Section 147Section 14ASection 154

6. Ground No. 2 relates to disallowance conformed by Ld. CIT (A) under rule 8D (iii) of Income Tax Rules, 1963. 6.1. At the outset, Ld.Counsel submitted that, this issue stands squarely covered by following observation by Hon’ble Supreme Court in case of Maxopp Investments vs CIT reported in (2018) 91 taxman.com 154, in favour of assessee: “36. There

THE ACIT, , KOCHI vs. M/S.FEDERAL BANK LTD, KOCHI

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

ITA 309/COCH/2020[2012-13]Status: DisposedITAT Cochin12 Dec 2022AY 2012-13

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

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin
Section 147Section 14ASection 154

6. Ground No. 2 relates to disallowance conformed by Ld. CIT (A) under rule 8D (iii) of Income Tax Rules, 1963. 6.1. At the outset, Ld.Counsel submitted that, this issue stands squarely covered by following observation by Hon’ble Supreme Court in case of Maxopp Investments vs CIT reported in (2018) 91 taxman.com 154, in favour of assessee: “36. There

ACIT, KOCHI vs. FEDERAL BANK LTD, ALUVA

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

ITA 34/COCH/2020[2009-10]Status: DisposedITAT Cochin12 Dec 2022AY 2009-10

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

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin
Section 147Section 14ASection 154

6. Ground No. 2 relates to disallowance conformed by Ld. CIT (A) under rule 8D (iii) of Income Tax Rules, 1963. 6.1. At the outset, Ld.Counsel submitted that, this issue stands squarely covered by following observation by Hon’ble Supreme Court in case of Maxopp Investments vs CIT reported in (2018) 91 taxman.com 154, in favour of assessee: “36. There

ACIT, KOCHI vs. FEDERAL BANK LTD, ALUVA

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

ITA 33/COCH/2020[2008-09]Status: DisposedITAT Cochin12 Dec 2022AY 2008-09

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

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin
Section 147Section 14ASection 154

6. Ground No. 2 relates to disallowance conformed by Ld. CIT (A) under rule 8D (iii) of Income Tax Rules, 1963. 6.1. At the outset, Ld.Counsel submitted that, this issue stands squarely covered by following observation by Hon’ble Supreme Court in case of Maxopp Investments vs CIT reported in (2018) 91 taxman.com 154, in favour of assessee: “36. There