VALSAN CHIYYABATH NARAYANAN,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

penalty u/s. 271(1)(c) of the Act. The undisputed facts of the case are that the appellant had not filed regular return of income under the provisions of section 1391(1) of the Act. The appellant has disclosed income of Rs. 63,06,068/-in response to notice u/s. 148

VALSAN CHIYYABATH NARAYANAN,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

penalty u/s. 271(1)(c) of the Act. The undisputed facts of the case are that the appellant had not filed regular return of income under the provisions of section 1391(1) of the Act. The appellant has disclosed income of Rs. 63,06,068/-in response to notice u/s. 148

VALSAN CHIYYABATH,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

penalty u/s. 271(1)(c) of the Act. The undisputed facts of the case are that the appellant had not filed regular return of income under the provisions of section 1391(1) of the Act. The appellant has disclosed income of Rs. 63,06,068/-in response to notice u/s. 148

VALSAN CHIYYABATH NARAYANAN,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

penalty u/s. 271(1)(c) of the Act. The undisputed facts of the case are that the appellant had not filed regular return of income under the provisions of section 1391(1) of the Act. The appellant has disclosed income of Rs. 63,06,068/-in response to notice u/s. 148

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

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 order dated 23.12.2019 passed u/s. 143(3) r.w.s. 147 of the Act at total loss of Rs. 3,36,83,226/-. While doing so, the AO disallowed

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

In the result, the assessee’s appeal is partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

271(1)(c) of the Act vide notice u/s. 274 of even date: 2 Prakash R. Nair v. Dy.CIT, Central Circle i. Claim for deduction u/s 80IA(Rs.68,82,867/-) was rejected. ii. Bank interest of Rs. 3,13,508/- was assessed as ‘Income from Other Sources’. iii. The claim for deduction u/s 80HHC was restricted with reference to section

CHRISTUDANAM YASSAYA,THIRUVANANTHAPURAM vs. ITO, WARD 1(1), THIRUVANANTHAPURAM

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

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2011-12 Christudanam Yassaya .......... Appellant Bathel Kp 17A Maruthoor, Vattapara P.O. Thiruvananthapuram 695028 [Pan: Acmpy4412C] Vs. The Income Tax Officer, Ward-1(1) .......... Respondent Aayakar Bhavan, Kowdiar Thiruvananthapuram 695003

u/s. 148 of the Act in terms of provisions of Explanation 3 to 4 Christudanam Yassaya section 271(1)(c) of the Act. Therefore the AO is justified in levying the penalty

SRI HARIKUTTAN T,KAYAMKULAM vs. INCOME TAX OFFICER WARD 2, ALLEPPEY

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

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember Harikuttan T. The Income Tax Officer (2) 1, Edayilaveetil Tharayil Aayakar Bhavan Njakkanal P.O., Pathiyoor Vs. Alappuzha Co0Llectorate Kayalmulam 690533 Alappuzha 688011 [Pan:Alrpt7536J] (Appellant) (Respondent) Appellant By: Shri M.S. Venkitachalam, Ca Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R. Date Of Hearing:08.08.2023 Date Of Pronouncement:03.11.2023 O R D E R Per Sanjay Arora, Am This Is An Appeal By Assessee Challenging The Confirmation Of Penalty Levied Under Section 270A Of The Income Tax Act, 1961 (The Act) For Assessment Year (Ay) 2017-18 Vide Order Dated 17/02/2022, By The First Appellate Authority, Being The Commissioner Of Income Tax, Nfac [Cit(A)] Vide It’S Order Dated 06.07.2022. 2.1 The Brief Background Facts Of The Case Are That The Assessee, A Retired Defence Personnel, Is A Registered Money Lender Under The Kerala Money Lenders Act (Kml Act), Lending Money On Interest Against Mortgage Of Loan. For The Relevant Year He Returned, Besides Pension, Income From This Business At Rs.2,05,691. On Verification, It Was Found By The Assessing Officer (Ao) That The Assessee Was Maintaining Six Bank Accounts, I.E., Three Each With Two Banks, Being South Indian Bank (Sib) & State Bank Of India (Sbi). Transactions With The Former Were Undisclosed. The Reason Explained Was That The Gold Pawned By His Customers With Him For Availing Loan, Was In Turn Mortgaged With This Bank To Source Funds For Further Lending. These

148; (f) the amount of deemed total income reassessed as per the provisions of section 115JB or section 115JC, as the case may be, is greater than the deemed total income assessed or reassessed immediately before such reassessment; (g) the income assessed or reassessed has the effect of reducing the loss or converting such loss into income. (3) The amount

THE KATTOOR SERVICE COOPERATIVE BANK LIMITED,THRISSUR vs. INCOME TAX OFFICER, WARD 2(1), THRISSUR, THRISSUR

In the result, the appeals filed by the assessee stand dismissed

148 nor the notices issued u/s. 142(1) of the Act. In\nthe circumstances, the AO was constrained to make best judgement\nassessment u/s. 144 of the Act assessing the cash deposit of Rs.\n25,88,71,177/- as unexplained money of the appellant vide order\ndated 25.03.2022 passed u/s. 147 r.w.s. 144 r.w.s. 144B of the Act.\n5.\nBeing

ATTU PURATTU ISMAIL,THALASSERY vs. INCOME TAX OFFICER, WARD-2, , KANNUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2013-14 Attupurattu Ismail .......... Appellant Attupuratt House, Thalassesry, Kannur 670676 [Pan: Abfbi7471M] Vs. The Income Tax Officer, Ward-2, Kannur ......... Respondent Assessee By: Shri Ananthakrishnan R. Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 07.11.2025 Date Of Pronouncement: 19.11.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 01.09.2025 For Assessment Year (Ay) 2013-14. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. The Return Of Income For Ay 2013-14 Was Filed On 22.03.2014 Disclosing Total Income Of Rs. 2,63,300/-. The Search & Seizure Operations U/S. 132 Of The Income Tax Act, 1961 (The Act) Was Conducted In The Business Premises Of Parco Group Of Concerns

penalty u/s. 271(1)(c) of the Act on the case of assessment made u/s. 148 of the Act. In our opinion provisions of Explanation 5A to section

THE KATTOOR SERVICE COOPERATIVE BANK LIMITED,THRISSUR vs. INCOME TAX OFFICER, WARD 2(1), THRISSUR, THRISSUR

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

148 nor the notices issued u/s. 142(1) of the Act. In the circumstances, the AO was constrained to make best judgement assessment u/s. 144 of the Act assessing the cash deposit of Rs. 25,88,71,177/- as unexplained money of the appellant vide order dated 25.03.2022 passed u/s. 147 r.w.s. 144 r.w.s. 144B of the Act. 5. Being

THE KATTOOR SERVICE COOPERATIVE BANK LIMITED,THRISSUR vs. INCOME TAX OFFICER, WARD 2(1), THRISSUR, THRISSUR

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

148 nor the notices issued u/s. 142(1) of the Act. In the circumstances, the AO was constrained to make best judgement assessment u/s. 144 of the Act assessing the cash deposit of Rs. 25,88,71,177/- as unexplained money of the appellant vide order dated 25.03.2022 passed u/s. 147 r.w.s. 144 r.w.s. 144B of the Act. 5. Being

BADER SULTAN KAKAD,PALAKKAD vs. ITO, WARD-1, PALAKKAD

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2016-17 Bader Sultana Kakad .......... Appellant 11/460 Metro Bazar, Market Road Palakkad 678014 [Pan: Agtpb9696A] Vs. The Income Tax Officer, Ward -1, Palakkad ......... Respondent Assesseeby: Shri Sivadas Chettor, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

u/s 271 (1)(b) of the Act for non-compliance of three notices aggregate amount of penalty of Rs. 30,000/-. During the penalty proceeding the assessee made details compliance on dated 04/05/2024in response to notice of the Ld. AO dated 02/05/2024. But the penalty is imposed by the Ld. AO by rejecting the submission of the assessee. Aggrieved assessee

SHOBHA RAMAKRISHNANA NAIR,ERNAKULAM vs. ITO, WARD 2, ALUVA

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

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessment Year: 2016-17 Shobha Ramakrishnan Nair Karthika Sebipuram Ito Ernakulam Ward-2 Vs. Manjapra So Aluva Kerala 683581 Pan No :Awrpr5406L Appellant Respondent Appellant By : None Respondent By : Smt. Leena Lal, Sr. D.R. Date Of Hearing : 30.01.2025 Date Of Pronouncement : 02.04.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 22.12.2023 Vide Din & Order No. Itba/Nfac/S/250/2023-24/1059003947(1) For The Ay 2016- 17 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”).

u/s. 147 r.w.s. 144 r.w.s. 144B of the Act dated 29.03.2022, the assessee preferred an appeal before the CIT(A)/NFAC 6. The ld. CIT(A)/NFAC dismissed the appeal of the assessee in limine by not condoning the delay of 5 months in filing the appeal as requested by the assessee in column 14 & 15 of form

FRANCIS LISTON,ERNAKULAM vs. INCOME TAX OFFICER, NONCORPORATE WARD 2(1), KOCHI, ERNAKULAM

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Inturi Rama Rao & Shri Anikesh Banerjee

section 250 of the Income tax Act, 1961 (for brevity, the “the Act”), date of order 22/07/2025 for Assessment year 2011-12. The impugned order emanated from the order of the Learned Income-tax Officer, Non-Corp. Ward-2(1), Kochi (for brevity, the “Ld. AO”) passed u/s 271(1)(c) of the Act, date of order 19/08/2016

AKM ERECTORS,ERNAKULAM vs. COMMISSIONER OF INCOME TAX, KOCHI, KOCHI

In the result, the appeals filed by the assessee stand partly allowed

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

u/s. 148 of the Act by treating the entire contract receipts as income of the appellant. No doubt, the AO was justified in resorting to best judgement assessment. However, the approach adopted by the AO in taxing the entire contract receipts as taxable income is unreasonable and arbitrary. Even in the case of best judgement assessment, assessment of income should

AKM ERECTORS,ERNAKULAM vs. COMMISSIONER OF INCOME-TAX, KOCHI, KOCHI

In the result, the appeals filed by the assessee stand partly allowed

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

u/s. 148 of the Act by treating the entire contract receipts as income of the appellant. No doubt, the AO was justified in resorting to best judgement assessment. However, the approach adopted by the AO in taxing the entire contract receipts as taxable income is unreasonable and arbitrary. Even in the case of best judgement assessment, assessment of income should