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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

5 is allowed in favour of the Appellant.” 12. Suffice to say, it is very much evident that the Revenue’s endeavour herein is to revive the proportionate interest expenditure disallowance in assessee’s case relating to it’s exempt income. As against this, learned CIT(A) has recorded a categoric finding that the assessee had nowhere utilized

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

5 is allowed in favour of the Appellant.” 12. Suffice to say, it is very much evident that the Revenue’s endeavour herein is to revive the proportionate interest expenditure disallowance in assessee’s case relating to it’s exempt income. As against this, learned CIT(A) has recorded a categoric finding that the assessee had nowhere utilized

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

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

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

43-B of the Income Tax Act,1961 has held that the new proviso to Section 43B should be given retrospective effect from the inception on the ground that the proviso was added to remedy unintended consequences and supply an obvious omission. The proviso ensured reasonable interpretation and retrospective effect would serve the object behind the enactment. The aforesaid view

AYUR GREEN AYURVEDA HOSPITALS PRIVATE LIMITED,MALAPPURAM vs. DCIT, CPC, BENGALURU, BENGALURU

In the result, the assessee’s appeal is dismissed

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmiayurgreen Ayurveda Hospsitals Vs Dcit, Private Limited Cpc, Door No. 1/301 Ayurgreen Bengaluru. Ayurveda Hospitals, Kaladi Mlp Edappal, Malappuram-679585. (Appellant) (Respondent) Pan No. Aaica 4294 M

43-B If the assessee fails to deposit the PF, ESIC etc Contribution before the due dates as per the respective Acts. Effect of Section 43B on unpaid liability towards contributions to any provident fund or superannuation fund or any fund set up under the provisions of the 6 Ayurgreen Ayurveda Hospitals Pvt. Ltd. Employees' State Insurance

KITEX GARMENTS LIMITED,KIZHAKKAMBALAM vs. DCIT 1(1), CORPORATE CIRCLE, KOCHI

In the result, appeal filed by the assessee stands dismissed

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

disallowed the excess depreciation on residential building of Rs. 6,48,210/-. 3. The factual background of the above addition is that during the previous year relevant to the assessment year under consideration the appellant company received capital subsidy of Rs. 5,93,99,739/- and interest subsidy of Rs. 12,05,749/- under the Technology Upgradation Fund Scheme (TUFS

MALABAR CEMENTS LIMITED,PALAKKAD vs. ACIT, PALAKKAD

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

5. The Revenue on the other hand supports the impugned disallowance of depreciation that the same is no more admissible as it ought to have been claimed in the year of acquisition of the fixed asset(s) only. 6. We find no merit in the Revenue’s instant technical argument in the light of the corresponding statutory provision

M/S.MUKKAM MEGA MULTIPURPOSE CO-OP SOCEITY LTD,KOZHIKKODE vs. THE ITO, KOZHIKKODE

In the result, the appeal by the assessee is allowed for statistical purposes and the stay petition is dismissed

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

disallowing chapter VI A deduction of Rs 43,17,817/-since the appellant has filed the return under section 139(4) of the act and made the above claim. 3. The return for the above was filed on 25/09/2020 by claiming deduction under section SOP of the act to an extent of Rs 43,17,817/- and both the Centralized

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

43(1) of the Act. Accordingly, disallowed the claim for allowance as revenue expenditure of pre-operative expenditure ofRs.13,28,53,754/-. iv. Disallowance of excess claim of deduction u/s. 35(2AB) – The appellant company made claim for deduction of Rs. 80,28,91.589/- u/s. 35(2AB) of the Act as against the expenditure certified by DSIR

JULIUS RUBEN,KOCHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), KOCHI

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

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

5. 31.10.2014 Indusind Industrial Laser Range Finder Nil 28,350.00 Suppliers 6. 28.06.2014 Jaims Transports Payment for hire Yes 30,000.00 charges Total 6,55,650.00 10. The invoices clearly show that payments were made for purchase of fixed assets, which were capitalized in the books of account. The expenditure incurred, therefore, was not charged to the profits and loss

TRICHUR DIST ELECTRICITY BOARD EMPLOYEES CO-OP SOCIETY LIMITED,THRISSUR vs. ITO, WARD-2(1), THRISSUR

In the result, the appeal filed by the assessee is allowed as indicated above

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

43,513. 2 ITA No.496/Coch/2024. Thrissur Dist Electricity Board Employees Co-op So Ltd. Subsequently, the case of the assessee was selected for scrutiny and statutory notices were issued to the assessee. During the course of assessment proceedings, the Assessing Officer took a view that the assessee is not entitled for the deduction of interest income earned from co-operative

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

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