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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

MALANADU MILK PRODUCERS SOCIETY,KOTTAYAM vs. DCIT, EXEMPTION, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

Bench: Shri George George K. & Ms. Padmavathy S.

disallowed. ITA NoS.632 & 633/Coch/2022 Page 3 of 12 4. In such circumstances, you are requested to explain why the assessment order passed u/s 143(1) of the Act in your case on 11/10/2019 shall not be treated as erroneous and be revised accordingly.” 4. The assessee filed a detailed reply dated 2.3.2022 (pg. 45 to 51 of PB) where

MALANADU FARMERS SOCIETY ,KOTTAYAM vs. DCIT EXEMPTIONS, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

Bench: Shri George George K. & Ms. Padmavathy S.

disallowed. ITA NoS.632 & 633/Coch/2022 Page 3 of 12 4. In such circumstances, you are requested to explain why the assessment order passed u/s 143(1) of the Act in your case on 11/10/2019 shall not be treated as erroneous and be revised accordingly.” 4. The assessee filed a detailed reply dated 2.3.2022 (pg. 45 to 51 of PB) where

THE CHORODE SERVICE CO-OPERATIVE BANK LTD, LL139,CHORODE vs. ITO, WARD-2(2), KOZHIKODE

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

71,530/- are hereby rejected. 5.3 Addition of Rs. 1,59,602/-: The Assessing Authority held that interest income from Savings Bank accounts at SBI & ICICI Bank was assessable under the head 'income from other sources' and not under the head 'business income', and hence, was not found eligible for deduction under section 80P(2

THE CHORODE SERVICE CO-OP BANK LTD LL139,CHORODE vs. ITO, WARD-2(2), KOZHIKODE

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

71,530/- are hereby rejected. 5.3 Addition of Rs. 1,59,602/-: The Assessing Authority held that interest income from Savings Bank accounts at SBI & ICICI Bank was assessable under the head 'income from other sources' and not under the head 'business income', and hence, was not found eligible for deduction under section 80P(2

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

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

71,759/- (d) Disallowance under Section 36(1)(iii) of the Act of 2 Assessment Year 2013-2014 INR.12,68,911/- The Assessee

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

disallowance of Rs. 39,11,162/- under section 40(a)(ia) amounted to underreporting of income overlooking the fact that the appellant had deducted tax at source in all eligible cases and could not provide complete data due to technical issues faced by them on account of merger of 13 District Co-operative banks and short of time. 2

ELANTHOOR SERVICE CO OPER BANK LIMITED,ELANTHOOR vs. ITO, WARD 2, THIRUVALLA

In the result, the appeal filed by the assessee is allowed

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2020-21

Section 80P(2)(a)(i), there is no justification to deny the deduction with respect to the income received during the carrying on of such banking activity. 4. The appellant is bound to maintain liquidity and the appellant had deposited amounts based on business prudence. Apart from this, the surplus fund available in the banking activities cannot be kept idle

INFOPARKS KERALA,COCHIN vs. THE ACIT, COCHIN

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

disallowance thereof would obtain for years prior to AY 2015-2016. 4. We have heard the parties, and perused the material on record. 4.1 Taking the first issue, the Revenue’s understanding of the amended s. 2(15) stands endorsed by the Apex Court in Ahmedabad Urban Development Authority 3 ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala

INFOPARKS KERALA,TRIVANDRUM vs. THE JT DIRECTOR OF IT (OSD) EXEM), COCHIN

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

disallowance thereof would obtain for years prior to AY 2015-2016. 4. We have heard the parties, and perused the material on record. 4.1 Taking the first issue, the Revenue’s understanding of the amended s. 2(15) stands endorsed by the Apex Court in Ahmedabad Urban Development Authority 3 ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala

INFOPARKS KERALA,TRIVANDRUM vs. THE JT DIRECTOR OF IT (OSD) EXEM), COCHIN

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

disallowance thereof would obtain for years prior to AY 2015-2016. 4. We have heard the parties, and perused the material on record. 4.1 Taking the first issue, the Revenue’s understanding of the amended s. 2(15) stands endorsed by the Apex Court in Ahmedabad Urban Development Authority 3 ITA Nos.75-77/Coch/2015 (AYs. 2009-10 to 11-12) Infopark Kerala

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

2,86,39,000/-. It is submitted that the appellant company made provisions for various expenditures. Since the payee was not identifiable, TDS was not made on such payment and, therefore, in the immediately next year the provision was reversed and deduction was claimed on the basis of actual expenditure. Reliance in this regard were placed on the following decisions

THE KERALA MINERALS AND METALS LIMITED,KOLLAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, KOLLAM

In the result, the appeal filed by the assessee stands allowed

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am Assessment Year: 2012-13 The Kerala Minerals & Metals Ltd. .......... Appellant Sankaramangalam, Chavara, Kollam 691583 [Pan: Aaact8118R] Vs. Asst. Commissioner Of Income Tax .......... Respondent Circle - 1, Kollam Appellant By: Shri Rajeev R., Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 13.05.2025 Date Of Pronouncement: 16.05.2025

section 37(1) has no application as it is effective from AY 2015-16 and moreover the expenditure is not incurred mandatorily u/s. 135 of the Companies Act, 2013 but the expenditure is incurred wholly and exclusively for acquiring goodwill of the community. The ld. Pr. CIT considered the above explanation and held that non-examination of the issue renderd

APTIV CONNECTION SYSTEMS INDIA PRIVATE LIMITED,KOCHI, KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), KOCHI, ERNAKULAM, KERALA

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowing section 10A deduction of Rs.56,48,936/- which has been upheld in the CIT(A)’s detailed discussion as under: - “4.2 Ground No. 2 relates to addition at Rs. 56,48,936/- on account of excess deduction claimed u/s 10A of the Act. The appellant is a private limited company engaged in the manufacturing of connectors, providing computer aided

APTIV CONNECTION SYSTEMS INDIA PRIVATE LIMITED,KOCHI, KERALA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), KOCHI, KERALA

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowing section 10A deduction of Rs.56,48,936/- which has been upheld in the CIT(A)’s detailed discussion as under: - “4.2 Ground No. 2 relates to addition at Rs. 56,48,936/- on account of excess deduction claimed u/s 10A of the Act. The appellant is a private limited company engaged in the manufacturing of connectors, providing computer aided