M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

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

2. It is submitted that the appellant is legally and factually eligible for deduction of the interest paid in respect of capital borrowed and the claim has to be allowed as per the provisions contained in section 36(1)(iii) of the Act, 3. In view of the contention raised in Ground No.2 the disallowance u/s. 37

DCIT, THIRUVALLA vs. MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

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

disallow the expenditure incurred on public deposits. At this point, it I.T.A. Nos. 69-72/Coch/2018 & 73-75/Coch/2018 would be relevant to examine the provisions of Section 37(1) of the I.T. Act and the same is as under:- "General. 37 (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being

DCIT, THIRUVALLA vs. MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

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

disallow the expenditure incurred on public deposits. At this point, it I.T.A. Nos. 69-72/Coch/2018 & 73-75/Coch/2018 would be relevant to examine the provisions of Section 37(1) of the I.T. Act and the same is as under:- "General. 37 (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being

THE ACIT, CIRCLE-1, THIRUVALLA, THIRUVALLA vs. MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE, PATHANAMTHITTA

In the result, the appeals of the Revenue are partly allowed for statistical

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

disallow the expenditure incurred on public deposits. At this point, it I.T.A. Nos. 69-72/Coch/2018 & 73-75/Coch/2018 would be relevant to examine the provisions of Section 37(1) of the I.T. Act and the same is as under:- "General. 37 (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being

THE ACIT, THIRUVALLA vs. M/S.MUTHOOT PROPERTIES & INVESTMENTS, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

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

disallow the expenditure incurred on public deposits. At this point, it I.T.A. Nos. 69-72/Coch/2018 & 73-75/Coch/2018 would be relevant to examine the provisions of Section 37(1) of the I.T. Act and the same is as under:- "General. 37 (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being

DCIT, THIRUVALLA vs. MUTHOOT PROPERTIES & INVESTMENTS,, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

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

disallow the expenditure incurred on public deposits. At this point, it I.T.A. Nos. 69-72/Coch/2018 & 73-75/Coch/2018 would be relevant to examine the provisions of Section 37(1) of the I.T. Act and the same is as under:- "General. 37 (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being

THE ACIT, THIRUVALLA vs. M/S.MUTHOOT PROPERTIES & INVESTMENTS, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

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

disallow the expenditure incurred on public deposits. At this point, it I.T.A. Nos. 69-72/Coch/2018 & 73-75/Coch/2018 would be relevant to examine the provisions of Section 37(1) of the I.T. Act and the same is as under:- "General. 37 (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being

DCIT, THIRUVALLA vs. MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

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

disallow the expenditure incurred on public deposits. At this point, it I.T.A. Nos. 69-72/Coch/2018 & 73-75/Coch/2018 would be relevant to examine the provisions of Section 37(1) of the I.T. Act and the same is as under:- "General. 37 (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

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

disallow only 2% of expenses incurred towards exempted income. Thus, this ground of appeal of the assessee is partly allowed. Thus, appeal of the assessee is partly allowed. ITA No. 61/Coch/2015 :Assessee’s Appeal : AY 2006-07 8. The assessee has raised the following grounds of appeal: Under Normal Provisions of the Income

THE DCIT, COCHIN vs. M/S.ASPINWALL & CO. LTD, COCHIN

In the result,the appeal of the Revenue in ITA No

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

disallow only 2% of expenses incurred towards exempted income. Thus, this ground of appeal of the assessee is partly allowed. Thus, appeal of the assessee is partly allowed. ITA No. 61/Coch/2015 :Assessee’s Appeal : AY 2006-07 8. The assessee has raised the following grounds of appeal: Under Normal Provisions of the Income

M/S ASPINWALL & CO.,LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

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

disallow only 2% of expenses incurred towards exempted income. Thus, this ground of appeal of the assessee is partly allowed. Thus, appeal of the assessee is partly allowed. ITA No. 61/Coch/2015 :Assessee’s Appeal : AY 2006-07 8. The assessee has raised the following grounds of appeal: Under Normal Provisions of the Income

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

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

disallow only 2% of expenses incurred towards exempted income. Thus, this ground of appeal of the assessee is partly allowed. Thus, appeal of the assessee is partly allowed. ITA No. 61/Coch/2015 :Assessee’s Appeal : AY 2006-07 8. The assessee has raised the following grounds of appeal: Under Normal Provisions of the Income

PLANT LIPIDS (P) LTD.,KADAYIRUPPU vs. DCIT , CORPORATE CIRCLE-2(1), KOCHI

In the result appeal filed by assessee stands allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessmentyear:2020-21 Plant Lipids (P) Ltd. Kadayiruppu Po Kolenchery Dcit, Vs. Kerala 682 311 Corporate Circle-2(1) Kochi Pan No : Aabcp6061C Appellant Respondent Appellant By : Shri Thomson Thomas, A.R. Respondent By : Shri Sanjit Kumar Das, D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 O R D E R Perkeshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ao, Assessment Unit, Income Tax Department Dated 19.6.2024 Vide Din No.Itba/Ast/S/143(3)/2024- 25/1065876641(1) For The Ay 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”). 2. The Assessee Has Raised Following Grounds Of Appeal: Plant Lipids (P) Ltd., Kolencherry, Kerala Page 2 Of 8

disallowance of CSR expenditure under explanation 2 to section 37(1) of the Act applies only in the context of determining

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