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 is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with Rule 8D. 7

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 is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with Rule 8D. 7

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 is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with Rule 8D. 7

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.71,07,988/- which is only in the nature of a provision. He could hardly dispute the clinching fact that even the learned Assessing Officer’s corresponding assessment in para 2 nowhere raised such an issue of capital write off. We make it clear that we are dealing with an assessment framed u/s. 143(3) r.w.s

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.71,07,988/- which is only in the nature of a provision. He could hardly dispute the clinching fact that even the learned Assessing Officer’s corresponding assessment in para 2 nowhere raised such an issue of capital write off. We make it clear that we are dealing with an assessment framed u/s. 143(3) r.w.s

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.71,07,988/- which is only in the nature of a provision. He could hardly dispute the clinching fact that even the learned Assessing Officer’s corresponding assessment in para 2 nowhere raised such an issue of capital write off. We make it clear that we are dealing with an assessment framed u/s. 143(3) r.w.s

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowance of Rs.71,07,988/- which is only in the nature of a provision. He could hardly dispute the clinching fact that even the learned Assessing Officer’s corresponding assessment in para 2 nowhere raised such an issue of capital write off. We make it clear that we are dealing with an assessment framed u/s. 143(3) r.w.s

THE PARAKODE SERVICE CO-OP BANK LTD,ADOOR vs. THE ITO,, KOLLAM

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahuthe Parakode Service Co-Op. The Income Tax Officer Bank Ltd. Ward 4, Aayakar Bhavan Vs. Parakode, Adoor Karbala Junction Pathanamthitta 691554 Kollam 691001 Pan – Aaajt1587B Appellant Respondent

Section 139(1) for AY 2018- 19, i.e. 30.09.2019 extended up to 31.10.2019, therefore, statutorily the appellant is not eligible to claim exemption claimed u/s 80P of the Act. In light of these facts the disallowance made by the CPC is confirmed. This ground of appeal is dismissed.” 7

ASIANET SATELLITE COMMUNICATIONS LIMITED,THIRUVANANTHAPURAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, THIRUVANANTHAPURAM

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

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K, Jm

section (43B), the provisions of gratuity payable to approved gratuity fund is allowable as deduction u/s. 40A(7) of the Act as held by the Hon'ble Kerala High Court in the case of CIT vs. Common Welfare Trust (P.) Ltd. [2004] 269 ITR 290 (Ker.). 8. On the other hand, ld. Sr. DR submits that in absence of claim

ASIANET SATELLITE COMMUNICATIONS LIMITED,THIRUVANANTHAPURAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, THIRUVANANTHAPURAM

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

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K, Jm

section (43B), the provisions of gratuity payable to approved gratuity fund is allowable as deduction u/s. 40A(7) of the Act as held by the Hon'ble Kerala High Court in the case of CIT vs. Common Welfare Trust (P.) Ltd. [2004] 269 ITR 290 (Ker.). 8. On the other hand, ld. Sr. DR submits that in absence of claim

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

7. The Revenue is indeed fair enough in not pinpointing any distinction in facts or law; as the case may be. The assesee’s instant third substantive ground is allowed going by the principle of judicial consistency. 8. Lastly comes the assessee’s fourth ground seeking to delete section 36(1)(vii) disallowance

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

7. The Revenue is indeed fair enough in not pinpointing any distinction in facts or law; as the case may be. The assesee’s instant third substantive ground is allowed going by the principle of judicial consistency. 8. Lastly comes the assessee’s fourth ground seeking to delete section 36(1)(vii) disallowance

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

7. The Revenue is indeed fair enough in not pinpointing any distinction in facts or law; as the case may be. The assesee’s instant third substantive ground is allowed going by the principle of judicial consistency. 8. Lastly comes the assessee’s fourth ground seeking to delete section 36(1)(vii) disallowance

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

7. The Revenue is indeed fair enough in not pinpointing any distinction in facts or law; as the case may be. The assesee’s instant third substantive ground is allowed going by the principle of judicial consistency. 8. Lastly comes the assessee’s fourth ground seeking to delete section 36(1)(vii) disallowance

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

7. The Revenue is indeed fair enough in not pinpointing any distinction in facts or law; as the case may be. The assesee’s instant third substantive ground is allowed going by the principle of judicial consistency. 8. Lastly comes the assessee’s fourth ground seeking to delete section 36(1)(vii) disallowance

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

7. The Revenue is indeed fair enough in not pinpointing any distinction in facts or law; as the case may be. The assesee’s instant third substantive ground is allowed going by the principle of judicial consistency. 8. Lastly comes the assessee’s fourth ground seeking to delete section 36(1)(vii) disallowance

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

section 2(24(x). 6. This issue was raised in a prominent newspapers at that time. The said newspaper cuttings has been attached herewith for your kind perusal and records. 7. The proposed disallowance

THE FEDERAL BANK LTD,ALUVA vs. THE ACIT, KOCHI

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

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

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.” ITA Nos. 745 to 747/Coch/2019 ITA Nos. 33 to 35, 272 to 275, 309 to 311/Coch/2020 Page 6 of 28 The conclusion of the Hon’ble Court was therefore that prior