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 of the 1961 Act read with Rule 8D(2)(ii) of the 1962 Rules , on account of proportionate disallowance of interest expenses is not sustainable in the eyes of law, keeping in view judgment and order of Hon'ble Supreme Court in the case of South India Bank Limited v. CIT , reported in (2021) 130 taxmann.com 178

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 of the 1961 Act read with Rule 8D(2)(ii) of the 1962 Rules , on account of proportionate disallowance of interest expenses is not sustainable in the eyes of law, keeping in view judgment and order of Hon'ble Supreme Court in the case of South India Bank Limited v. CIT , reported in (2021) 130 taxmann.com 178

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 of the 1961 Act read with Rule 8D(2)(ii) of the 1962 Rules , on account of proportionate disallowance of interest expenses is not sustainable in the eyes of law, keeping in view judgment and order of Hon'ble Supreme Court in the case of South India Bank Limited v. CIT , reported in (2021) 130 taxmann.com 178

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 36(1)(va) disallowance on the ground that the assessee ought to have credited the employees’ contribution to PF & ESI within the specified due date under the corresponding statute than going by the “due” date of filing the return u/s. 139(1) of the Act. Suffice to say, case law Checkmate Services (P) Ltd., vs. CIT [2022] 143 taxmann.com

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 36(1)(va) disallowance on the ground that the assessee ought to have credited the employees’ contribution to PF & ESI within the specified due date under the corresponding statute than going by the “due” date of filing the return u/s. 139(1) of the Act. Suffice to say, case law Checkmate Services (P) Ltd., vs. CIT [2022] 143 taxmann.com

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 36(1)(va) disallowance on the ground that the assessee ought to have credited the employees’ contribution to PF & ESI within the specified due date under the corresponding statute than going by the “due” date of filing the return u/s. 139(1) of the Act. Suffice to say, case law Checkmate Services (P) Ltd., vs. CIT [2022] 143 taxmann.com

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 36(1)(va) disallowance on the ground that the assessee ought to have credited the employees’ contribution to PF & ESI within the specified due date under the corresponding statute than going by the “due” date of filing the return u/s. 139(1) of the Act. Suffice to say, case law Checkmate Services (P) Ltd., vs. CIT [2022] 143 taxmann.com

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

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. M/S.FEDERAL BANK LTD, 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

ACIT, KOCHI vs. FEDERAL BANK LTD, ALUVA

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

ACIT, KOCHI vs. FEDERAL BANK LTD, ALUVA

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

ACIT, KOCHI vs. FEDERAL BANK LTD, ALUVA

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