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

disallowance of interest expenditure DCIT, Corporate Circle 2(1), Kochi v. SFO Technologies Private Limited can be made by invoking provisions of Section 14A read with Rule 8D, by holding as under: “27

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

disallowance of interest expenditure DCIT, Corporate Circle 2(1), Kochi v. SFO Technologies Private Limited can be made by invoking provisions of Section 14A read with Rule 8D, by holding as under: “27

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

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

disallowance of interest expenditure DCIT, Corporate Circle 2(1), Kochi v. SFO Technologies Private Limited can be made by invoking provisions of Section 14A read with Rule 8D, by holding as under: “27

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 144, Rule 8D of the Income-tax Rules provides for the mechanism to determine the quantum of such disallowance. (ii) In terms of the provisions of Rule 8D, the amount to be disallowed shall be the aggregate of (i) expenses directly incurred to earn exempt income, (ii) interest expense (not directly attributable to any exempt income) worked

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 144, Rule 8D of the Income-tax Rules provides for the mechanism to determine the quantum of such disallowance. (ii) In terms of the provisions of Rule 8D, the amount to be disallowed shall be the aggregate of (i) expenses directly incurred to earn exempt income, (ii) interest expense (not directly attributable to any exempt income) worked

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 144, Rule 8D of the Income-tax Rules provides for the mechanism to determine the quantum of such disallowance. (ii) In terms of the provisions of Rule 8D, the amount to be disallowed shall be the aggregate of (i) expenses directly incurred to earn exempt income, (ii) interest expense (not directly attributable to any exempt income) worked

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 144, Rule 8D of the Income-tax Rules provides for the mechanism to determine the quantum of such disallowance. (ii) In terms of the provisions of Rule 8D, the amount to be disallowed shall be the aggregate of (i) expenses directly incurred to earn exempt income, (ii) interest expense (not directly attributable to any exempt income) worked

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

27,15,858/-. Thus, a total amount of Rs. 45, 30,81, 080/- was arrived at; eligible for deduction. The provision created being Rs. 97, 03,05,677/-. There was a disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

27,15,858/-. Thus, a total amount of Rs. 45, 30,81, 080/- was arrived at; eligible for deduction. The provision created being Rs. 97, 03,05,677/-. There was a disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

27,15,858/-. Thus, a total amount of Rs. 45, 30,81, 080/- was arrived at; eligible for deduction. The provision created being Rs. 97, 03,05,677/-. There was a disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

27,15,858/-. Thus, a total amount of Rs. 45, 30,81, 080/- was arrived at; eligible for deduction. The provision created being Rs. 97, 03,05,677/-. There was a disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

27,15,858/-. Thus, a total amount of Rs. 45, 30,81, 080/- was arrived at; eligible for deduction. The provision created being Rs. 97, 03,05,677/-. There was a disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

27,15,858/-. Thus, a total amount of Rs. 45, 30,81, 080/- was arrived at; eligible for deduction. The provision created being Rs. 97, 03,05,677/-. There was a disallowance of Rs. 51,72,24,597/-, which was added back as income. 10. The specific contention raised by the learned Senior Counsel for the assessee Bank is that

THE ACIT, COCHIN vs. M/S. KANNAN DEVAN HILLS PLANTATIONS CO., P. LTD, IDUKKI

In the result, the appeals filed by the assessee are allowed and the appeals filed

Bench: S/Shri George George K., Jm & Manjunatha G., Am

section 10(30) of the Act, the alternate plea raised, namely Tea Board subsidy should be taken as capital receipt, has been rendered infructuous and dismiss the additional ground raised as dismissed. 15.2 As regards the claim of restricting disallowance by invoking the provisions of Rule 8d r.w.s. 14A of the Act, we have restricted the disallowance to Rs.2,27

THE ACIT, COCHIN vs. M/S. KANNAN DEVAN HILLS PLANTATIONS CO., P. LTD, IDUKKI

In the result, the appeals filed by the assessee are allowed and the appeals filed

Bench: S/Shri George George K., Jm & Manjunatha G., Am

section 10(30) of the Act, the alternate plea raised, namely Tea Board subsidy should be taken as capital receipt, has been rendered infructuous and dismiss the additional ground raised as dismissed. 15.2 As regards the claim of restricting disallowance by invoking the provisions of Rule 8d r.w.s. 14A of the Act, we have restricted the disallowance to Rs.2,27

M/S.KANNAN DEVAN HILLS PLANTATIONS CO. P. LTD,MUNNAR vs. THE ACIT, TRIVANDRUM

In the result, the appeals filed by the assessee are allowed and the appeals filed

Bench: S/Shri George George K., Jm & Manjunatha G., Am

section 10(30) of the Act, the alternate plea raised, namely Tea Board subsidy should be taken as capital receipt, has been rendered infructuous and dismiss the additional ground raised as dismissed. 15.2 As regards the claim of restricting disallowance by invoking the provisions of Rule 8d r.w.s. 14A of the Act, we have restricted the disallowance to Rs.2,27

M/S.KANNAN DEVAN HILLS PLANTATIONS CO. P. LTD,MUNNAR vs. THE ACIT, COCHIN

In the result, the appeals filed by the assessee are allowed and the appeals filed

Bench: S/Shri George George K., Jm & Manjunatha G., Am

section 10(30) of the Act, the alternate plea raised, namely Tea Board subsidy should be taken as capital receipt, has been rendered infructuous and dismiss the additional ground raised as dismissed. 15.2 As regards the claim of restricting disallowance by invoking the provisions of Rule 8d r.w.s. 14A of the Act, we have restricted the disallowance to Rs.2,27

M/S.KANNAN DEVAN HILLS PLANTATIONS CO. P. LTD,MUNNAR vs. THE ACIT, COCHIN

In the result, the appeals filed by the assessee are allowed and the appeals filed

Bench: S/Shri George George K., Jm & Manjunatha G., Am

section 10(30) of the Act, the alternate plea raised, namely Tea Board subsidy should be taken as capital receipt, has been rendered infructuous and dismiss the additional ground raised as dismissed. 15.2 As regards the claim of restricting disallowance by invoking the provisions of Rule 8d r.w.s. 14A of the Act, we have restricted the disallowance to Rs.2,27