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92 results for “disallowance”+ Section 133(6)clear

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Key Topics

Section 250119Section 143(3)57Section 4051Disallowance19Section 80P18Addition to Income17Deduction17Section 26315Section 3(1)10Section 14A

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

In the result, this appeal filed by Revenue in ITA

ITA 402/COCH/2020[2013-14]Status: DisposedITAT Cochin24 Feb 2022AY 2013-14

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

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

6. The learned CIT(A) has failed to note that the Board vide Circular No.5 of 2014, has clarified that the disallowance is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with

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

Showing 1–20 of 92 · Page 1 of 5

10
Section 92C7
Natural Justice6

In the result, this appeal filed by Revenue in ITA

ITA 404/COCH/2020[2016-17]Status: DisposedITAT Cochin24 Feb 2022AY 2016-17

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

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

6. The learned CIT(A) has failed to note that the Board vide Circular No.5 of 2014, has clarified that the disallowance is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with

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

In the result, this appeal filed by Revenue in ITA

ITA 401/COCH/2020[2012-13]Status: DisposedITAT Cochin24 Feb 2022AY 2012-13

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

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

6. The learned CIT(A) has failed to note that the Board vide Circular No.5 of 2014, has clarified that the disallowance is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with

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

In the result, this appeal filed by Revenue in ITA

ITA 400/COCH/2020[2010-11]Status: DisposedITAT Cochin24 Feb 2022AY 2010-11

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

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

6. The learned CIT(A) has failed to note that the Board vide Circular No.5 of 2014, has clarified that the disallowance is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with

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

In the result, this appeal filed by Revenue in ITA

ITA 403/COCH/2020[2014-15]Status: DisposedITAT Cochin24 Feb 2022AY 2014-15

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

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

6. The learned CIT(A) has failed to note that the Board vide Circular No.5 of 2014, has clarified that the disallowance is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with

MR.THOMAS DANIEL,PATHANAMTHITTA vs. THE ITO, WARD-4, THIRUVALLA

In the result, the appeal of the assessee is dismissed

ITA 68/COCH/2018[2014-15]Status: DisposedITAT Cochin09 Nov 2018AY 2014-15

Bench: S/Shri Chandra Poojari, Am & George George K., Jm I.T.A. No.68/Coch/2018 Assessment Year : 2014-15

Section 194ASection 40Section 44A

6) of section 44AB during the financial year immediately preceding the financial year, which such interest is credited or paid, shall be liable to deduct income-tax under this section.” “Section 2(28A) - “interest" means interest payable in any manner in respect of any moneys borrowed or debt incurred (including a deposit, claim or other similar right or obligation

RAJU JOSEPH VAYALAT,ERNAKULAM vs. ITO, WARD-2(5), KOCHI

In the result, the appeal of the assessee is dismissed

ITA 273/COCH/2024[2013-2014]Status: DisposedITAT Cochin26 Aug 2025AY 2013-2014

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 133(6)Section 143(3)Section 68

133(6) to the said creditor, no confirmation was received. The assessee also failed to produce any evidence regarding the claimed cost of improvement of Rs. 35,77,949 while computing long-term capital gains on sale of land. In the absence of any corroborative material, both the AO and the CIT(A) were justified in making/sustaining the additions. Even

AVINISSERY SERVICE CO-OPERATIVE BANK LTD,THRISSUR vs. THE INCOME TAX OFFICER WARD 2(1),THRISSUR, THRISSUR

ITA 569/COCH/2025[2016-17]Status: DisposedITAT Cochin27 Oct 2025AY 2016-17
Section 143(3)Section 250Section 5Section 80Section 80P

disallow deductions claimed under section 80P of the Income-tax Act, notwithstanding that mere nomenclature or registration certificates issued under the Kerala Act would show that the assessees are primary agricultural credit societies. These divergent decisions led to a reference order dated 9-7-2018 to a Full Bench of the Kerala High Court.* - *5. The Full Bench

THE ITO, TRIVANDRUM vs. M/S.PERRORKADA SERVICE CO-OP BANK LTD, TRIVANDRUM

In the result, the appeal of the Revenue in I

ITA 47/COCH/2019[2013-14]Status: DisposedITAT Cochin26 Jun 2019AY 2013-14

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 194A(3)(viia)Section 195Section 263Section 40Section 40A(3)Section 80P

6. The next issue for the assessment year 2013-14 is with regard to deduction u/s. 80P(2)(a)(i) of the Act. This issue was allowed by the CIT(A) in the light of the order of the Tribunal in the case of Kizhathadiyoor Co-operative Bank Limited for AY 2009-10 in ITA No. 525/Coch/2014, order dated

M/S.PERRORKADA SERVICE CO-OP BANK LTD,TRIVANDRUM vs. THE ITO, TRIVANDRUM

In the result, the appeal of the Revenue in I

ITA 141/COCH/2017[2013-14]Status: DisposedITAT Cochin26 Jun 2019AY 2013-14

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 194A(3)(viia)Section 195Section 263Section 40Section 40A(3)Section 80P

6. The next issue for the assessment year 2013-14 is with regard to deduction u/s. 80P(2)(a)(i) of the Act. This issue was allowed by the CIT(A) in the light of the order of the Tribunal in the case of Kizhathadiyoor Co-operative Bank Limited for AY 2009-10 in ITA No. 525/Coch/2014, order dated

M/S.PEROORKADA SERVICE CO-OP BANK LTD,TRIVANDRUM vs. THE ITO, WD-2(1), TRIVANDRUM, TRIVANDRUM

In the result, the appeal of the Revenue in I

ITA 400/COCH/2018[2014-15]Status: DisposedITAT Cochin26 Jun 2019AY 2014-15

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 194A(3)(viia)Section 195Section 263Section 40Section 40A(3)Section 80P

6. The next issue for the assessment year 2013-14 is with regard to deduction u/s. 80P(2)(a)(i) of the Act. This issue was allowed by the CIT(A) in the light of the order of the Tribunal in the case of Kizhathadiyoor Co-operative Bank Limited for AY 2009-10 in ITA No. 525/Coch/2014, order dated

M/S.PEROORKADA SERVICE CO-OP BANK LTD,TRIVANDRUM vs. THE ITO, WD-2(1), TRIVANDRUM, TRIVANDRUM

In the result, the appeal of the Revenue in I

ITA 93/COCH/2018[2014-15]Status: DisposedITAT Cochin26 Jun 2019AY 2014-15

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 194A(3)(viia)Section 195Section 263Section 40Section 40A(3)Section 80P

6. The next issue for the assessment year 2013-14 is with regard to deduction u/s. 80P(2)(a)(i) of the Act. This issue was allowed by the CIT(A) in the light of the order of the Tribunal in the case of Kizhathadiyoor Co-operative Bank Limited for AY 2009-10 in ITA No. 525/Coch/2014, order dated

M/S.PERRORKADA SERVICE CO-OP BANK LTD,TRIVANDRUM vs. THE ITO, TRIVANDRUM

In the result, the appeal of the Revenue in I

ITA 563/COCH/2018[2013-14]Status: DisposedITAT Cochin26 Jun 2019AY 2013-14

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 194A(3)(viia)Section 195Section 263Section 40Section 40A(3)Section 80P

6. The next issue for the assessment year 2013-14 is with regard to deduction u/s. 80P(2)(a)(i) of the Act. This issue was allowed by the CIT(A) in the light of the order of the Tribunal in the case of Kizhathadiyoor Co-operative Bank Limited for AY 2009-10 in ITA No. 525/Coch/2014, order dated

THE MAHADEVIKAD SERVICE CO-OP BANK LTD,ALAPPUZHA vs. THE ITO WARD 5 , ALAPPUZHA

ITA 289/COCH/2023[2017-18]Status: DisposedITAT Cochin03 Jan 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Smt. Leena Lal, Sr. DR
Section 133(6)Section 139Section 139(1)Section 142(1)Section 144Section 80A(5)Section 80P

disallowed the assessee's claim under section 80P by wrongly holding that the assessee had not filed any return of income for the year. 5. The CIT[A] should have considered the return of income filed by the assessee and granted the deduction under section 80P as claimed in the return. 5. The CIT[A] should have noted that

KERALA STATE ELECTRICITY BOARD LTD,THIRUVANANTHAPURAM vs. THE ACIT, CIR-1(1), TVM, TVM

In the result, all the appeals filed by the assessee stands allowed for statistical purposes

ITA 136/COCH/2023[2017-18]Status: DisposedITAT Cochin12 Jul 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri R Rajeev, CA
Section 143(3)Section 263Section 28Section 3(1)Section 40Section 5

section 40(a)(iib) is satisfied, no disallowance could be made u/s. 40(a)(iib) of the act. In the interest of justice, we remit this issue back to the Ld.AO to carry out a de novo assessment. The Ld.AO is directed to carry out Page 8 of 8 ITA Nos. 133 to 137/Coch/2023 necessary verification by issuing 133(6

KERALA STATE ELECTRICITY BOARD LTD,THIRUVANANTHAPURAM vs. THE ACIT, CIR-1(1), TVM, TVM

In the result, all the appeals filed by the assessee stands allowed for statistical purposes

ITA 137/COCH/2023[2018-19]Status: DisposedITAT Cochin12 Jul 2024AY 2018-19

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri R Rajeev, CA
Section 143(3)Section 263Section 28Section 3(1)Section 40Section 5

section 40(a)(iib) is satisfied, no disallowance could be made u/s. 40(a)(iib) of the act. In the interest of justice, we remit this issue back to the Ld.AO to carry out a de novo assessment. The Ld.AO is directed to carry out Page 8 of 8 ITA Nos. 133 to 137/Coch/2023 necessary verification by issuing 133(6

KERALA STATE ELECTRICITY BOARD LTD,THIRUVANANTHAPURAM vs. THE ACIT, CIR-1(1), TVM, TVM

In the result, all the appeals filed by the assessee stands allowed for statistical purposes

ITA 134/COCH/2023[2015-16]Status: DisposedITAT Cochin12 Jul 2024AY 2015-16

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri R Rajeev, CA
Section 143(3)Section 263Section 28Section 3(1)Section 40Section 5

section 40(a)(iib) is satisfied, no disallowance could be made u/s. 40(a)(iib) of the act. In the interest of justice, we remit this issue back to the Ld.AO to carry out a de novo assessment. The Ld.AO is directed to carry out Page 8 of 8 ITA Nos. 133 to 137/Coch/2023 necessary verification by issuing 133(6

KERALA STATE ELECTRICITY BOARD LTD,THIRUVANANTHAPURAM vs. THE ACIT, CIR-1(1), TVM, TVM

In the result, all the appeals filed by the assessee stands allowed for statistical purposes

ITA 133/COCH/2023[2014-15]Status: DisposedITAT Cochin12 Jul 2024AY 2014-15

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri R Rajeev, CA
Section 143(3)Section 263Section 28Section 3(1)Section 40Section 5

section 40(a)(iib) is satisfied, no disallowance could be made u/s. 40(a)(iib) of the act. In the interest of justice, we remit this issue back to the Ld.AO to carry out a de novo assessment. The Ld.AO is directed to carry out Page 8 of 8 ITA Nos. 133 to 137/Coch/2023 necessary verification by issuing 133(6

KERALA STATE ELECTRICITY BOARD LTD,THIRUVANANTHAPURAM vs. THE ACIT, CIR-1(1), TVM, TVM

In the result, all the appeals filed by the assessee stands allowed for statistical purposes

ITA 135/COCH/2023[2016-17]Status: DisposedITAT Cochin12 Jul 2024AY 2016-17

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri R Rajeev, CA
Section 143(3)Section 263Section 28Section 3(1)Section 40Section 5

section 40(a)(iib) is satisfied, no disallowance could be made u/s. 40(a)(iib) of the act. In the interest of justice, we remit this issue back to the Ld.AO to carry out a de novo assessment. The Ld.AO is directed to carry out Page 8 of 8 ITA Nos. 133 to 137/Coch/2023 necessary verification by issuing 133(6

SYEDALI EBRAHIM,THIRUVANANTHAPURAM vs. ITO WARD-1(1), THIRUVANANTHAPURAM

ITA 571/COCH/2025[2017-18]Status: DisposedITAT Cochin22 Sept 2025AY 2017-18

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

For Appellant: Shri Padmanathan K. VFor Respondent: Smt. Leena Lal
Section 133(6)Section 143(3)Section 250Section 68

133(6) is factually incorrect, as the bank had sanctioned the loan to the appellant and has issued a confirmation letter to this effect. F. The appellant craves to add, modify, substitute, alter or delete any of the grounds in this appeal.” 3. The relevant facts in brief are that the Assessment for the Assessment Year 2016-17 was framed