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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction in assessee’s favour and against the Revenue, as under:- “23

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction in assessee’s favour and against the Revenue, as under:- “23

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction in assessee’s favour and against the Revenue, as under:- “23

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction in assessee’s favour and against the Revenue, as under:- “23

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction in assessee’s favour and against the Revenue, as under:- “23

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.8,39,91,691 representing long term finance made available to the “eligible business” in the relevant assessment years. The tribunal’s earlier order (supra) has also dealt with the very same issue of section 36(1)(viii) deduction in assessee’s favour and against the Revenue, as under:- “23

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

23]\n■ Having said so, now lets come back to the question in the present\nappeals i.e., whether an assessee can make a claim for deduction under Chapter VI-\nA, for the first time in the return of income filed in response to the notice issued\nunder section 153A, pursuant to search conducted under section 132. This legal\nposition

DCIT, TRIVANDRUM vs. BRAHMOS AEROSPACE( THIRUVANANTHAPURAM) LTD, TRIVANDRUM

In the result, the appeal filedby

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am Deputy Commissioner Brahmos Aerospace Of Income Tax, (Thiruvananthapuram) Ltd., Circle-1(1), V. Chackai, Thiruvananthapuram Beach Post, Kerala Tiruvananthapuram, Kerala Pan – Aabck2217K Appellant Respondent

23(Bom), the assesse can always present its claim before the appellate authorities for the first time even if the said claim is not made in the return of income filed with the Revenue, wherein Hon’ble Bombay High Court held as under: “10. A long line of authorities establish clearly that an assessee is entitled to raise additional grounds

M/S PERINGATTU HEALTH FOUNDATION PRIVATE,ERNAKULAM vs. ITO CORPORATE WARD 2(3), KOCHI

In the result, the assessee’s appeal is partly allowed

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

section 143(3) of the Income Tax Act, 1961 (‘the Act’) dated 14.12.2016 for assessment year (AY) 2014-2015. 2. The appeal, filed on 09.01.2023, is delayed by 148 days. It is accompanied by a sworn affidavit of even date by Dr. Thampi Mathew, Executive Director and Principal Officer, also signing the appeal memo before the first appellate authority

DY.COMMISSIONER OF INCOME TAX, THRISSUR vs. THE CSB BANK LTD, THRISSUR

In the result, the appeal of revenue is dismissed

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

disallowance of provisions of bad and doubtful debts to the extent of Rs. 57.57 crores is deleted. 3. The CIT(A) has erred on the following points while deleting the Book profit enhancement consequent to bad and doubtful debt the extent of Rs. 57.57 crores. 3.1. Vijaya Bank decision is applicable only for normal Income and not MAT Income [Minimum

HI-LITE BUILDERS PRIVATE LIMITED ,KOZHIKODE vs. DCIT, CENTRAL CIRCLE-1, KOZHIKODE, KOZHIKODE

In the result, the appeal by the assessee is allowed

Bench: Smt. Beena Pillai & Ms. Padmavathy S.Assessment Year : 2009-10

disallowance in the present Assessment Year. 22. In order to remedy this position and to remove hardships which were being caused to the assessees belonging to such second category, amendments have been made in the provisions of Section 40(a) (ia) by the Finance Act, 2010. 23. Section 40(a)(ia), as amended by Finance Act, 2010, with effect from

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

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

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

disallowing such claims had also taken support from the decision of a Supreme Court, wherein it has been laid down that the Assessing Officer cannot entertain a claim for deduction otherwise than by filing a revised return. Since the assessee neither made any such claim in the original return filed under section 139(1), nor in any regular assessment proceedings

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

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

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

disallowing such claims had also taken support from the decision of a Supreme Court, wherein it has been laid down that the Assessing Officer cannot entertain a claim for deduction otherwise than by filing a revised return. Since the assessee neither made any such claim in the original return filed under section 139(1), nor in any regular assessment proceedings

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

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

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

disallowing such claims had also taken support from the decision of a Supreme Court, wherein it has been laid down that the Assessing Officer cannot entertain a claim for deduction otherwise than by filing a revised return. Since the assessee neither made any such claim in the original return filed under section 139(1), nor in any regular assessment proceedings

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

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

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

disallowing such claims had also taken support from the decision of a Supreme Court, wherein it has been laid down that the Assessing Officer cannot entertain a claim for deduction otherwise than by filing a revised return. Since the assessee neither made any such claim in the original return filed under section 139(1), nor in any regular assessment proceedings

THE ACIT, CIRCLE-1(1), THRRISSUR vs. MANJILAS AGRO FOODS PVT. LTD., THRISSUR

In the result, all the appeals by the assessee are partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.

23. Proviso to section 147 provides that where any income chargeable to tax has escaped assessment for such assessment ITA Nos.32 to 34/Coch/2022 Page 6 of 18 year by reason of the failure on the part of the assessee to make a return under section 139, consequences will follow. According to the learned counsel for the revenue, return under section

MANJILAS AGRO FOODS PVT. LTD,THRISSUR vs. THACIT,CIRCLE-1(1 ), THRISSUR

In the result, all the appeals by the assessee are partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.

23. Proviso to section 147 provides that where any income chargeable to tax has escaped assessment for such assessment ITA Nos.32 to 34/Coch/2022 Page 6 of 18 year by reason of the failure on the part of the assessee to make a return under section 139, consequences will follow. According to the learned counsel for the revenue, return under section

MANJILAS AGRO FOOD PVT.LTD.,THRISSUR vs. THE ITO,WARD-1(2),, THRISSUR

In the result, all the appeals by the assessee are partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.

23. Proviso to section 147 provides that where any income chargeable to tax has escaped assessment for such assessment ITA Nos.32 to 34/Coch/2022 Page 6 of 18 year by reason of the failure on the part of the assessee to make a return under section 139, consequences will follow. According to the learned counsel for the revenue, return under section

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

23,08,219 services 13 Provision of corporate information 2,32,10,5456 technology services 14 Investment in equity 50,02,98,250 15 Reimbursement of expenses 1,07,78,001 16 Recovery of expenses 3,69,14,146 3. On noticing the above international transactions, the AO referred the matter to the Transfer Pricing Officer (TPO) u/s. 92CA(1