MUTHOOT BANKERS,TRIVANDRUM vs. THE ACIT CIRCLE 1(2), TRIVANDRUM

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A r.w. rule 8D disallowance(s) amounting to Rs.88,68,993/- and Rs. 96,41,136/-; assessment year-wise

MUTHOOT BANKERS,TRIVANDRUM vs. THE ACIT CIRCLE 1(2), TRIVANDRUM

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A r.w. rule 8D disallowance(s) amounting to Rs.88,68,993/- and Rs. 96,41,136/-; assessment year-wise

THE VAZHAYOOR SERVICE CO OPERATIVE BANK LTD,MALAPPURAM vs. ITO, WARD-2, TRIRUR

In the result, appeal filed by the appellant stands allowed

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharythe Vazhayoor Service Co-Op. Bank Ltd. .......... Appellant No.D1989, Head Office, Azhinhlam P.O., Ernad, Malappuram Dist., Kerala-673632 [Pan: Aacat 5682 J] Vs. Ito, Ward-2, Tirur .......... Respondent Appellant By: None Respondent By: Smt. Leena Lal, Sr. Dr Date Of Hearing: 22.08.2025 Date Of Pronouncement: 28.08.2025 O R D E R Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee-Cooperative Society Directed Against The Order Passed By The Learned Commissioner Of Income Tax (A)/Nfac, Delhi [For Short, ‘Cit(A)’] Dated 19.06.2025 Passed U/S. 250 Of The Income Tax Act, 1961 (For Short, 'The Act') For The Assessment Year (A.Y.) 2014-15. 2. Brief Facts Of The Case Are That Appellant Is A Cooperative Society Registered Under The Kerala Co-Operative Societies Act, 1969. It Is Classified As Primary Agricultural Credit Cooperative Society. It Is Engaged In The Business Of Accepting Deposits From Member & Providing Credit Facilities To Its Member. The Return Of 2 The Vazhayoor Service Co-Op. Bank Ltd. Income For The A.Y. 2014-15 Was Filed On 30/03/2015 Disclosing Nil Income After Claiming Deduction Under Section 80P Of The Act. Against The Said Return Of Income, The Assessment Was Completed By The Ito, Ward-3, Tirur (For Short, ‘Ao’) Vide Order Dated 19/12/2016 Passed Under Section 143(3) Of The Act At A Total Income Of Rs. 1,72,40,710/- By Disallowing The Claim For Deduction Under Section 80P Of The Act By Holding That The Appellant Is A Cooperative Bank & Hit By The Provisions Of Section 80P(4) Of The Act.

section 80P of the Act, however, confirmed the addition of Rs. 5,96,757/- made on account of disallowance of provisions

CHANDIROOR SERVICE CO-OPERATIVE BANK LTD,ALAPPUZHA vs. JCIT, RANGE 1, ALAPPUZHA

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

disallowing deduction under Section 80P and determining the total income at Rs. 32,96,560. During the assessment proceedings the Assessing

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

96,832 Disallowance of pre-operative expenditure 13,28,53,754 Disallowance of Excess claim of deduction u/s. 31,21,05,589 35(2AB) Disallowance u/s. 40(a)(i) 14,06,31,409 Unrealised foreign exchange loss o capital assets 2,18,26,172 Difference out of TDS reconciliation 9,28,097 Disallowance of year end provisions

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

section 148 for A.Y.2009-10 are as 1. Brought forward losses of A.Y. 2008-09 have not been correctly declared by the assessee in the return. 2. The Assessee has claimed deduction u/s 10A of Rs.40,96,155/- from business loss of Rs.24,20,60,716/- which is not proper. 3. Additional depreciation of Rs.17,73,077/- has been claimed

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

section 148 for A.Y.2009-10 are as 1. Brought forward losses of A.Y. 2008-09 have not been correctly declared by the assessee in the return. 2. The Assessee has claimed deduction u/s 10A of Rs.40,96,155/- from business loss of Rs.24,20,60,716/- which is not proper. 3. Additional depreciation of Rs.17,73,077/- has been claimed

APTIV CONNECTION SYSTEMS INDIA PRIVATE LIMITED,KOCHI, KERALA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), ERNAKULAM, KERALA

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 148 for A.Y.2009-10 are as 1. Brought forward losses of A.Y. 2008-09 have not been correctly declared by the assessee in the return. 2. The Assessee has claimed deduction u/s 10A of Rs.40,96,155/- from business loss of Rs.24,20,60,716/- which is not proper. 3. Additional depreciation of Rs.17,73,077/- has been claimed

MAHE SERVICE CO-OPERATIVE CREDIT SOCIETY LTD,KOZHIKODE vs. ITO,WARD-1 & TPS, KANNUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

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

96,065/-under section 80P of the Act in respect of the interest/Dividend received on investments with Co- operative Bank, which was disallowed

THE BALUSSERY REGIONAL CO-OPERATIVE BANK LIMITED,BALUSSERY vs. ITO, WARD-2(2), CALICUT

In the result, the assessee’s appeals are allowed in above terms

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Balussery Regional Co-Op. Income Tax Officer Bank Ltd. Ward - 2(2), Kozhikode Balussery P.O. Vs. Kozhikode 673612 [Pan: Aacab2821R] (Appellant) (Respondent)

96,200/- after claiming deduction under chapter-VI of the Act for Rs. 29,79,121/- which includes deduction u/s 80P(2)(a)(i) of the Act for Rs. 28,52,121/-. 2 Balussery Regional Co-op. Bank Ltd. 3. The AO during the assessment found that the interest income shown by the assessee includes an amount

KERALA STATE FINANCIAL ENTERPRISES LIMITED,THRISSUR vs. DCIT CIRCLE 1(1) & TPS, THRISSUR

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

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

section 143(3B) of the Act at a total income of Rs.396,29,16,115. While doing so, the Assessing Officer (AO) made following disallowances:- (i) Disallowance of provision for bad and doubtful debts. Rs.142,30,66,326 (ii) Disallowance u/s.36(1)(va) r.w.s. 2(24)(x) Rs. 6,61,577 (iii) Disallowance u/s.43B Rs. 4,79,102 (iv) Disallowances

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Das

sections 30 to 53[38], the following amounts shall not be deducted in computing the income chargeable under the head "Profits and gains of business or profession",— (a) in the case of any assessee— (b) in the case of any firm assessable as such,— (i) any payment of salary, bonus, commission or remuneration, by whatever name called (hereinafter referred

M/S SULAIKHA CLAY MINES,TRIVANDRUM vs. DCIT ,CIRCLE 1(2), TRIVANDRUM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Das

sections 30 to 53[38], the following amounts shall not be deducted in computing the income chargeable under the head "Profits and gains of business or profession",— (a) in the case of any assessee— (b) in the case of any firm assessable as such,— (i) any payment of salary, bonus, commission or remuneration, by whatever name called (hereinafter referred

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Das

sections 30 to 53[38], the following amounts shall not be deducted in computing the income chargeable under the head "Profits and gains of business or profession",— (a) in the case of any assessee— (b) in the case of any firm assessable as such,— (i) any payment of salary, bonus, commission or remuneration, by whatever name called (hereinafter referred

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Das

sections 30 to 53[38], the following amounts shall not be deducted in computing the income chargeable under the head "Profits and gains of business or profession",— (a) in the case of any assessee— (b) in the case of any firm assessable as such,— (i) any payment of salary, bonus, commission or remuneration, by whatever name called (hereinafter referred

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Das

sections 30 to 53[38], the following amounts shall not be deducted in computing the income chargeable under the head "Profits and gains of business or profession",— (a) in the case of any assessee— (b) in the case of any firm assessable as such,— (i) any payment of salary, bonus, commission or remuneration, by whatever name called (hereinafter referred

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Das

sections 30 to 53[38], the following amounts shall not be deducted in computing the income chargeable under the head "Profits and gains of business or profession",— (a) in the case of any assessee— (b) in the case of any firm assessable as such,— (i) any payment of salary, bonus, commission or remuneration, by whatever name called (hereinafter referred

LAKESHORE HOSPITAL AND RESEARCH CENTRE LIMITED,KOCHI vs. ACIT, CORPORATE CIRCLE 1(2), KOCHI

In the result, the assessee’s appeal is allowed

Bench: Shri Sanjay Arora & Shri Manomohan Daslakeshore Hospital & Rsearch Dy. Cit, Corporate Circle Centre Ltd. 1(1), C.R. Building, Xvi Maradu, Nh 47 Bye Pass Vs. Is Press Road, Netoor P.O., Kochi 682040 Kochi 682018 [Pan:Aaacl4923A] (Appellant) (Respondent)

disallowing Rs.21,96,064 qua the employee’s contribution u/s.36(1)(va) of the Act on account of it being paid belatedly on 16.2.2016, i.e., as against the due date of 15.2.2016. Reliance is placed on binding decisions by the Hon'ble jurisdictional High CourtinCIT vs. South India Corporation Ltd. [2020] 423 ITR 158 (Ker);CIT v. Harrisons Malayalam