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20 results for “disallowance”+ Section 221(1)clear

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Key Topics

Section 143(3)27Section 14A18Section 4015Disallowance14Section 271B12Deduction11Addition to Income10Section 80I9Section 698Section 68

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

1), Kochi v. SFO Technologies Private Limited “The Appellant in the course of hearing and submissions has segregated the explanation into three segments: a.Applicability of Section 14A disallowance on Foreign Investments b.Applicability of Section 14A disallowance for investments made in subsidiary companies as an extended arm of the business of the assessee. c.Applicability of Section 14A disallowance on other investments

6
Natural Justice6
Section 92C5

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

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

1), Kochi v. SFO Technologies Private Limited “The Appellant in the course of hearing and submissions has segregated the explanation into three segments: a.Applicability of Section 14A disallowance on Foreign Investments b.Applicability of Section 14A disallowance for investments made in subsidiary companies as an extended arm of the business of the assessee. c.Applicability of Section 14A disallowance on other investments

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

1), Kochi v. SFO Technologies Private Limited “The Appellant in the course of hearing and submissions has segregated the explanation into three segments: a.Applicability of Section 14A disallowance on Foreign Investments b.Applicability of Section 14A disallowance for investments made in subsidiary companies as an extended arm of the business of the assessee. c.Applicability of Section 14A disallowance on other investments

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

1), Kochi v. SFO Technologies Private Limited “The Appellant in the course of hearing and submissions has segregated the explanation into three segments: a.Applicability of Section 14A disallowance on Foreign Investments b.Applicability of Section 14A disallowance for investments made in subsidiary companies as an extended arm of the business of the assessee. c.Applicability of Section 14A disallowance on other investments

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

1), Kochi v. SFO Technologies Private Limited “The Appellant in the course of hearing and submissions has segregated the explanation into three segments: a.Applicability of Section 14A disallowance on Foreign Investments b.Applicability of Section 14A disallowance for investments made in subsidiary companies as an extended arm of the business of the assessee. c.Applicability of Section 14A disallowance on other investments

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

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

ITA 133/COCH/2017[2012-13]Status: DisposedITAT Cochin19 May 2020AY 2012-13

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

Section 14A

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

ITA 128/COCH/2017[2012-13]Status: DisposedITAT Cochin19 May 2020AY 2012-13

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

Section 14A

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

ITA 60/COCH/2015[2006-07]Status: DisposedITAT Cochin19 May 2020AY 2006-07

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

Section 14A

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

ITA 61/COCH/2015[2006-07]Status: DisposedITAT Cochin19 May 2020AY 2006-07

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

Section 14A

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

SRI.P. GOPALAKRISHNAN ALIAS DILEEP,ALUVA vs. THE ACIT, ALUVA

In the result, the appeal of the assessee is dismissed

ITA 164/COCH/2016[2009-10]Status: DisposedITAT Cochin01 Aug 2019AY 2009-10

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

Section 139Section 201Section 40

disallowance u/s. 40(a)(ia) of the Act, certain amounts were disclosed by the recipients in the return of income. 5. We have heard the rival submissions and perused the record. The issue before us is whether the assessee gets any benefit or his obligation is absolved if the recipient of the said has already paid taxes on the amounts

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 223/COCH/2023[2008-09]Status: DisposedITAT Cochin06 Aug 2024AY 2008-09

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

disallowing the advertisement expenses for not deducting the TDS. We find that the said amount was added based on the figures found place in the books of account and not based on the incriminating materials seized during the search. Therefore, when the AO made an assessment u/s. 153C of the Act, he cannot make addition u/s. 68 or 69 since

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 220/COCH/2023[2005-06]Status: DisposedITAT Cochin06 Aug 2024AY 2005-06

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

disallowing the advertisement expenses for not deducting the TDS. We find that the said amount was added based on the figures found place in the books of account and not based on the incriminating materials seized during the search. Therefore, when the AO made an assessment u/s. 153C of the Act, he cannot make addition u/s. 68 or 69 since

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 221/COCH/2023[2006-07]Status: DisposedITAT Cochin06 Aug 2024AY 2006-07

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

disallowing the advertisement expenses for not deducting the TDS. We find that the said amount was added based on the figures found place in the books of account and not based on the incriminating materials seized during the search. Therefore, when the AO made an assessment u/s. 153C of the Act, he cannot make addition u/s. 68 or 69 since

SANTHIMADAM AGROFARM TRUST,KOCHI vs. THE ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 222/COCH/2023[2007-08]Status: DisposedITAT Cochin06 Aug 2024AY 2007-08

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Ilaiyaraja K.S., Sr. DR
Section 132Section 142(1)Section 153CSection 194CSection 234ASection 40Section 68Section 69

disallowing the advertisement expenses for not deducting the TDS. We find that the said amount was added based on the figures found place in the books of account and not based on the incriminating materials seized during the search. Therefore, when the AO made an assessment u/s. 153C of the Act, he cannot make addition u/s. 68 or 69 since

ACIT, ERNAKULAM vs. M/S SKYLINE BUILDERS, ERNAKULAM

In the result, the appeals filed by the Revenue are dismissed

ITA 927/COCH/2024[2009-10]Status: DisposedITAT Cochin26 May 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Sundarasan S, CIT-DRFor Respondent: Sri.P.M.Veeramani, CA
Section 801B(10)Section 80I

221,498 cents. The section does not specify that each projects should be on a vacant land of one acre. The section does not prohibit more than one project in land extending more than one acre. The section does not specify the size or the number of projects that are required to be undertaken on a plot having a minimum

ACIT, KOCHI vs. M/S SKYLINE BUILDERS, ERNAKULAM

In the result, the appeals filed by the Revenue are dismissed

ITA 942/COCH/2024[2012-13]Status: DisposedITAT Cochin26 May 2025AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Sundarasan S, CIT-DRFor Respondent: Sri.P.M.Veeramani, CA
Section 801B(10)Section 80I

221,498 cents. The section does not specify that each projects should be on a vacant land of one acre. The section does not prohibit more than one project in land extending more than one acre. The section does not specify the size or the number of projects that are required to be undertaken on a plot having a minimum

ACIT, ERNAKULAM vs. M/S SKYLINE BUILDERS, ERNAKULAM

In the result, the appeals filed by the Revenue are dismissed

ITA 928/COCH/2024[2010-11]Status: DisposedITAT Cochin26 May 2025AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Sundarasan S, CIT-DRFor Respondent: Sri.P.M.Veeramani, CA
Section 801B(10)Section 80I

221,498 cents. The section does not specify that each projects should be on a vacant land of one acre. The section does not prohibit more than one project in land extending more than one acre. The section does not specify the size or the number of projects that are required to be undertaken on a plot having a minimum

KSEB EMPLOYEES CO OP SOCIETY,KALLARKUTTY vs. ITO,WARD 1 & TPS, THODUPUZHA

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 593/COCH/2024[2020-21]Status: DisposedITAT Cochin02 Apr 2025AY 2020-21

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessment Year: 2020-21 Kseb Employees Co-Op. Society Kallarkutty Kallarkutty Po Assessment Unit Vs. Idukki 685 562 Nfac Kerala Delhi Pan No : Aacak8820H Appellant Respondent Appellant By : Shri Mathew Joseph, A.R. Respondent By : Smt. Leena Lal, Sr. D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 02.04.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 30.4.2024 Vide Din & Order No. Itba/Nfac/S/250/2024-25/1064480180(1) For The Ay 2020- 21 Passed U/S. 250 Of The Income Tax Act,1961 (In Short “The Act”).

For Appellant: Shri Mathew Joseph, A.RFor Respondent: Smt. Leena Lal, Sr. D.R
Section 115BSection 143(2)Section 143(3)Section 250Section 68Section 80P(2)(a)

disallowed the amount of Rs. 23,13,641/- under the head any other allowable deduction. Further, the AO has also added increased unsecured loans amounting to Rs. 1,28,10,152/- (Rs. 4,80,63,221 – Rs. 3,52,53,069) as unexplained credit u/s 68 of the Act and brought to tax as per provision of section

KALLUMALA AGRICULTURAL COOPERATIVE BANK LTD NO HW 14,ALAPPUZHA vs. ITO, WARD 2, THIRUVALLA

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

ITA 119/COCH/2025[2015-16]Status: DisposedITAT Cochin30 Jun 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Sonjoy Sarma, Jm

For Appellant: Shri Sabu C S, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 271BSection 275Section 44ASection 80P

221/-. While the matter stood thus, the AO also issued a show cause notice U/s. 275 r.w.s 271B of the Act on 29/03/2022 calling upon the appellant to show cause as to why an order imposing penalty U/s. 271B of the Act cannot be passed. In response to the show cause notice, the appellant has filed a detailed explanation which

KALLUMALA AGRICULTURAL COOPERATIVE BANK LTD NO HW 14,ALAPPUZHA vs. ITO, WARD 2, THIRUVALLA

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

ITA 118/COCH/2025[2013-14]Status: DisposedITAT Cochin30 Jun 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Sonjoy Sarma, Jm

For Appellant: Shri Sabu C S, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 271BSection 275Section 44ASection 80P

221/-. While the matter stood thus, the AO also issued a show cause notice U/s. 275 r.w.s 271B of the Act on 29/03/2022 calling upon the appellant to show cause as to why an order imposing penalty U/s. 271B of the Act cannot be passed. In response to the show cause notice, the appellant has filed a detailed explanation which