M/S INDITRADE CAPITAL LTD (PREVIOUSLY KNOWN AS ,KOCHI vs. THE ITO, CORPORATE WARD1(1),, KOCHI

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

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

section 32(1)(ii) of the Act. Accordingly, the appellant made a claim for allowance of depreciation at the rate of 25% of the sum paid, placing reliance on the following decisions :- (i) Pentasoft Technologies Ltd. v. DDCIT, Tax case (Appeals) No.1195 by Hon’ble Madras High Court. (ii) Ind Global Corporate Fiannce (P) Ltd. v. ITO (2013) 33 taxmann.com

M/S INDITRADE CAPITAL LTD (PREVIOUSLY KNOWN AS ,KOCHI vs. THE ITO, CORPORATE WARD1(1),, KOCHI

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

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

section 32(1)(ii) of the Act. Accordingly, the appellant made a claim for allowance of depreciation at the rate of 25% of the sum paid, placing reliance on the following decisions :- (i) Pentasoft Technologies Ltd. v. DDCIT, Tax case (Appeals) No.1195 by Hon’ble Madras High Court. (ii) Ind Global Corporate Fiannce (P) Ltd. v. ITO (2013) 33 taxmann.com

M/S INDITRADE CAPITAL LTD (PREVIOUSLY KNOWN AS "JRG SECURITIES LTD"),KOCHI vs. THE ITO, CORPORATE WARD1(1),, KOCHI

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

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

section 32(1)(ii) of the Act. Accordingly, the appellant made a claim for allowance of depreciation at the rate of 25% of the sum paid, placing reliance on the following decisions :- (i) Pentasoft Technologies Ltd. v. DDCIT, Tax case (Appeals) No.1195 by Hon’ble Madras High Court. (ii) Ind Global Corporate Fiannce (P) Ltd. v. ITO (2013) 33 taxmann.com

M/S INDITRADE CAPITAL LTD (PREVIOUSLY KNOWN AS ,KOCHI vs. THE ITO, CORPORATE WARD1(1),, KOCHI

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

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

section 32(1)(ii) of the Act. Accordingly, the appellant made a claim for allowance of depreciation at the rate of 25% of the sum paid, placing reliance on the following decisions :- (i) Pentasoft Technologies Ltd. v. DDCIT, Tax case (Appeals) No.1195 by Hon’ble Madras High Court. (ii) Ind Global Corporate Fiannce (P) Ltd. v. ITO (2013) 33 taxmann.com

M/S INDITRADE CAPITAL LTD (PREVIOUSLY KNOWN AS ,KOCHI vs. THE ITO, CORPORATE WARD1(1),, KOCHI

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

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

section 32(1)(ii) of the Act. Accordingly, the appellant made a claim for allowance of depreciation at the rate of 25% of the sum paid, placing reliance on the following decisions :- (i) Pentasoft Technologies Ltd. v. DDCIT, Tax case (Appeals) No.1195 by Hon’ble Madras High Court. (ii) Ind Global Corporate Fiannce (P) Ltd. v. ITO (2013) 33 taxmann.com

KANNUR DISTRICT POLICE COOPERATIVE SOCIETY,KANNUR vs. ITO, WARD -1 & TPS, KANNUR

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

67 & SA.No.3/COCH./2024 Heard both the parties. Case file perused. 2. It appears at the outset that there is hardly had any need for us to give detailed consideration to the assessee’s sole substantive grievance seeking to reverse both the learned lower authorities action disallowing its section 80P deduction claimed by way of section 143(1

KINGS INFRA VENTURES LTD,THEVARA vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1 (2), KOCHI, KOCHI

In the result, the appeal by the assessee is dismissed

Bench: Shri Sanjay Arora & Shri Sandeep Gosainkings Infra Ventures Ltd. Asstt. Commissioner Of A-1, 1St Floor, Atria Apartment Income Tax, Opp. Gurudwara Temple Vs. Circle - 1(2) Perumanur Road Kochi Thevara, Kochi [Pan:Aaccv3411D] (Respondent) (Appellant) Appellant By: Shri Joseph Markose, Sr. Advocate Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R.

67,459. The Assessing Officer (AO) noting that the assessee’s business is of a Builder, disallowed the said claim, holding that there was no business (of Aqua Farm Culture), income of which could be computed. Relying on Perfect Pottery Co. Ltd. v. CIT [1987] 166 ITR 196 (Ker);S.P.V. Bank

M/S THURAYUR SERVICE CO -OP BANK LTD,KOZHIKODE vs. THE ITO WARD 2(1), KOZHIKODE

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1), both dated 14.12.2022, passed u/s. 143(3) of the Income Tax Act, 1961 (the Act). Cases called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2. During the course of hearing we find that both the learned lower authorities have disallowed assessee’s section 80P deduction claim of Rs.53,79,728/- and Rs.63,67

M/S THURAYUR SERVICE CO -OP BANK LTD,KOZHIKODE vs. THE ITO WARD 2(1), KOZHIKODE

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1), both dated 14.12.2022, passed u/s. 143(3) of the Income Tax Act, 1961 (the Act). Cases called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2. During the course of hearing we find that both the learned lower authorities have disallowed assessee’s section 80P deduction claim of Rs.53,79,728/- and Rs.63,67

HERCULES AUTOMOBILES INTERNATIONAL PRIVATE LIMITED,THIRUVANANTHAPURAM vs. AO TYPE-W, AAYAKAR BHAWAN, ALLEPPEY

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

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2012-13 Hercules Automobiles International P. Ltd. .......... Appellant Tc No.16/1860, Dpi Road, Thycaud S.O. Chempakassery, Thiruvananthapuram 695014 [Pan: Aabcn2898M] Vs. Dcit, Circle - 1, Alappuzha ......... Respondent Assessee By: Shri Jose Zachariah, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 20.11.2025

67,310/-. Subsequently, the AO formed an opinion that income escaped assessment to tax. Accordingly, a notice u/s. 148 was issued on 27.03.2019.In response to the notice u/s. 148, the appellant filed return of income on 18.09.2019 declaring loss of Rs. 3,71,34,545/-. Against the said return of income, the assessment was completed by the AO vide assessment

SUD-CHEMIE INDIA PRIVATE LIMITED,ALUVA vs. DCIT, CORPORATE CIR 2(1), ERNAKULAM

In the result, the appeal filed by the assessee in ITA No

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

1,94,42,031/- 40(a)(ii) 2 GSP paid in advance Rs. 6,65,49,118/- 3 Duty Drawback Rs. 3,76,00,382/- 4 Disallowance of royalty expenses in Rs.1,02,32,391/- eligible units 5 Administrative expenses Rs. 75,00,000/- Total 212,67,71,872/- 12. Being aggrieved, an appeal was filed before

M/S POYILOOR SERVICE CO-OP BANK LTD,KANNUR vs. ITO WARD 2 , KANNUR

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhassessment Year - 2014-15 Poyiloor Service Co-Op.Bank The Income Tax Officer-2, Kannothumchal Ltd., Poyiloor Post, Kannur. Vs. Pin – 670002 Pan Aacap8990R Kannur - 670 006 (Respondent) (Appellant)

disallowed the assessee’s section 80P(4) deduction. The Revenue further seeks to fortify the same on the ground that this assessee is in fact a co-operative bank as per the decision of the hon'ble jurisdictional high court in the case of Pr.CIT v. Mavilayi Service Co-operative Bank Ltd. [2019] 414 ITR 67

M/S CHIRAYINKEEZHU SERVICE CO-OPERATIVE BANK,CHIRAYINKEEZHU vs. ITO, WARD-2(5), TRIVANDRUM

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1), dated 03.03.2023, in proceedings u/s.143(3) of the Income Tax Act, 1961 (in short “the Act”). Heard both the parties. Case files perused. 2 ITA.No.913 & SA.No.202/COCH./2023 2. Suffice to say that we find during the course of hearing that both the learned lower authorities have disallowed the assessee’s section 80P(2) deduction claim representing

M/S.PUTHIYANGADI SERVICE CO-OP BANK,CALICUT vs. THE ITO WARD 1(3), CALICUT

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhassessment Year: 2017-18 M/S. Puthiyangadi Service Co- The Income Tax Officer Operative Bank Limited No.F1421 V. Ward 1(3), Alappuzha. Puthiyangadi Kozhikode – 673 021 Pan : Aacap0749C. (Appellant) (Respondent)

1) dated 27.12.2022 in proceedings u/s. 250 of the Income Tax Act, 1961 (the Act). Case called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2. Suffice to say that we find during the course of hearing that both the learned lower authorities have disallowed the assessee’s section 80P(2) deduction claim representing

KARASSERY SERVICE CO-OP BANK LTD,MUKKAM vs. THE ITO WARD 2(3), KOZHIKODE

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1) Cases called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2 ITA No.290-292/Coch/2023 Karassery SCB Ltd. 2. Suffice to say that we find during the course of hearing that both the learned lower authorities have disallowed the assessee’s section 80P(2) deduction claims representing its income derived from a district co- operative bank

KARASSERY SERVICE CO-OP BANK LTD,MUKKAM vs. THE ITO WARD 2(3), KOZHIKODE

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1) Cases called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2 ITA No.290-292/Coch/2023 Karassery SCB Ltd. 2. Suffice to say that we find during the course of hearing that both the learned lower authorities have disallowed the assessee’s section 80P(2) deduction claims representing its income derived from a district co- operative bank

KARASSERY SERVICE CO-OP BANK LTD,MUKKAM vs. THE ITO WARD 2(3), KOZHIKODE

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1) Cases called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2 ITA No.290-292/Coch/2023 Karassery SCB Ltd. 2. Suffice to say that we find during the course of hearing that both the learned lower authorities have disallowed the assessee’s section 80P(2) deduction claims representing its income derived from a district co- operative bank

CLAPPANA SERVICE CO-OPERATIVE BANK ALTD.,KARUNAGAPPALLY vs. ITO, WARD 1&TPS, ALAPPUZHA

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhassessment Year: 2017-2018 M/S. Clappana Service Co-Operative The Income Tax Officer Bank Limited No.867 V. Ward 1, Alappuzha. Cp/Viii/410 & 411, Clappana Po Karunagappally, Kollam – 690 525 Pan : Aabac2747A. (Appellant) (Respondent) Appellant By : Shri Rajakannan, Advocate Respondent By : Smt. V. Swarnalatha, Sr. D.R. Date Of Pronouncement : 25.09.2024 Date Of Hearing : 12.08.2024 O R D E R Per Bench : This Assessee’S Appeal For A.Y. 2017-18 Arises Against The National Faceless Appeal Centre, Delhi [Cit(A)]’S Din & Order No. Itba/ Nfac/S/250/2023-24/1055921666(1) Dated 11.09.2023, Passed U/S. 250 Of The Income Tax Act, 1961 (The Act).

1) dated 11.09.2023, passed u/s. 250 of the Income Tax Act, 1961 (the Act). Heard both the parties at length. Case file perused. 2. Suffice to say, we find during the course of hearing that both the learned lower authorities have disallowed the assessee’s section 80P(2) deduction claim representing its income derived from a district co-operative bank

THE THRIKKOVIL VATTOM PANCHAYATH SERVICE CO-OP BANK LTD,KOLLAM vs. ITO, KOLLAM

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowed the assessee’s section 80P(2)(a)(i) deduction claim. The Revenue further seeks to fortify the same on the ground that this assessee is in fact a co-operative bank as per the decision of the hon'ble jurisdictional high court in the case of Pr.CIT v. Mavilayi Service Co-operative Bank Ltd. [2019] 414 ITR 67