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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD ,PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

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

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271(1)(c) (INR) (INR) 3,73,478 3

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

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

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271(1)(c) (INR) (INR) 3,73,478 3

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD,PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

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

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271(1)(c) (INR) (INR) 3,73,478 3

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,MG ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

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

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271(1)(c) (INR) (INR) 3,73,478 3

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

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

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271(1)(c) (INR) (INR) 3,73,478 3

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

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

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271(1)(c) (INR) (INR) 3,73,478 3

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c) or u/s 36(1) (iii) r.w.s 37 of the Act, from making interest-free advances from out of interest- free funds, if such payments are made towards business purposes and if such payments have been made towards specified intents. yy) The following represent the statutory positions for the impugned A.Y. 2011-12 : (i) Section 14A of the Act provides

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c) or u/s 36(1) (iii) r.w.s 37 of the Act, from making interest-free advances from out of interest- free funds, if such payments are made towards business purposes and if such payments have been made towards specified intents. yy) The following represent the statutory positions for the impugned A.Y. 2011-12 : (i) Section 14A of the Act provides

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c) or u/s 36(1) (iii) r.w.s 37 of the Act, from making interest-free advances from out of interest- free funds, if such payments are made towards business purposes and if such payments have been made towards specified intents. yy) The following represent the statutory positions for the impugned A.Y. 2011-12 : (i) Section 14A of the Act provides

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c) or u/s 36(1) (iii) r.w.s 37 of the Act, from making interest-free advances from out of interest- free funds, if such payments are made towards business purposes and if such payments have been made towards specified intents. yy) The following represent the statutory positions for the impugned A.Y. 2011-12 : (i) Section 14A of the Act provides

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

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

3) dated 24/12/2019, though at nil, with the said 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

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

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

c) Disallowance under Section 36(1)(va) of the Act of INR.77,71,759/- (d) Disallowance under Section 36(1)(iii) of the Act of 2 Assessment Year 2013-2014 INR.12,68,911/- The Assessee has now preferred the present appeal challenging Final Assessment Order. The Assessee has raised 17 Grounds of Appeal which are taken up in seriatim hereinafter

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

c) is used in entirely different senses, in the relevant deduction clauses. The differentiation is also evident from the fact that each of these contributions is separately dealt with in different clauses of Section 36 (1). All these establish that Parliament, while introducing Section 36(1)(va) along with Section 2(24)(x), was aware of the distinction between

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

13 Apollo Tyres Ltd. modify any of the grounds appealed against during the course of hearing.” 7. The ground of appeal Nos. 1 & 2 are general in nature, require no adjudication. Ground Nos. 8 and 10 are not pressed by the learned counsel for the assessee, hence dismissed as not pressed. 8. The ground of appeal No. 3 challenges