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6 results for “reassessment”+ Deemed Dividendclear

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Key Topics

Section 2(22)(e)15Section 143(3)8Section 1487Section 2636Section 153A6Deemed Dividend6Addition to Income6Revision u/s 2634Search & Seizure3Section 147

NELLIKKOTE KUNHIPARI MOHAMMEDALI,KOZHIKODE vs. ACIT CIRCLE-1(1), KOZHIKODE

In the result, appeal filed by the assessee stands allowed

ITA 880/COCH/2024[2004-05]Status: DisposedITAT Cochin15 Jul 2025AY 2004-05

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Sri Suresh Sivanandan, CIT-DR
Section 143(3)Section 148Section 2(22)(e)Section 263

deemed dividend and taxed the same to the extent of accumulated profit available in hands of the lender companies. However, the addition was made under the protective basis as the substantive addition was made in the case of firm - N.K. Mohhammed Ali and Brothers. 7. Being aggrieved, an appeal was filed before the CIT(A) contending that the reassessment

2
Section 1322
Section 132A2

NELLIKKOTE KUNHIPARI MOHAMMEDALI,KOZHIKODE vs. ACIT CIRCLE-1(1), KOZHIKODE

In the result, appeal filed by the assessee stands allowed

ITA 881/COCH/2024[2007-08]Status: DisposedITAT Cochin15 Jul 2025AY 2007-08

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Sri Suresh Sivanandan, CIT-DR
Section 143(3)Section 148Section 2(22)(e)Section 263

deemed dividend and taxed the same to the extent of accumulated profit available in hands of the lender companies. However, the addition was made under the protective basis as the substantive addition was made in the case of firm - N.K. Mohhammed Ali and Brothers. 7. Being aggrieved, an appeal was filed before the CIT(A) contending that the reassessment

NELLIKKOTE KUNHIPARI MOHAMMEDALI,KOZHIKODE vs. ACIT CIRCLE-1(1), KOZHIKODE

In the result, appeal filed by the assessee stands allowed

ITA 888/COCH/2024[2006-07]Status: DisposedITAT Cochin15 Jul 2025AY 2006-07

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Sri Suresh Sivanandan, CIT-DR
Section 143(3)Section 148Section 2(22)(e)Section 263

deemed dividend and taxed the same to the extent of accumulated profit available in hands of the lender companies. However, the addition was made under the protective basis as the substantive addition was made in the case of firm - N.K. Mohhammed Ali and Brothers. 7. Being aggrieved, an appeal was filed before the CIT(A) contending that the reassessment

SRI.PARAYARUKANDY VETTATH GANGADHARAN,CALICUT vs. THE DCIT CIRCLE-1(1), CALICUT

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

ITA 157/COCH/2023[2007-08]Status: DisposedITAT Cochin12 Apr 2024AY 2007-08

Bench: Shri Sanjay Arora & Shri Manomohan Dasparayarukandy Vettath Gangadharan Dy. Cit, Circle - 1(1) Kerala Transport Company (Decd., Calicut Vs. Represented By Lrs.) K.T.C. Building, Ymca Calicut 673001 [Pan: Adhpg8318B] (Appellant) (Respondent)

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 147Section 148Section 149Section 150(1)Section 153Section 2(22)(e)Section 268A

deemed dividend at Rs.1,13,14,280/- relying on s. 150(1) of the Act, which provision reads as under: [ Provision for cases where assessment is in pursuance of an order on appeal, etc. 150. (1) Notwithstanding anything contained in section 149, the notice under section 148 may be issued at any time for the purpose of making an assessment

THE ACIT, KOZHIKODE vs. SHRI.. K.C.JAMES, GOA

In the result, the Revenue’s appeals and the assessee’s COs are dismissed

ITA 53/COCH/2022[2011-12]Status: DisposedITAT Cochin31 Jul 2023AY 2011-12

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Surendranath Rao, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132ASection 143(3)Section 153ASection 2(22)(e)Section 2(45)

deemed dividend, rejecting the assessee’s explanation, since accepted by the ld. CIT(A), that the same is a trade advance/s, to which therefore the provision of sec. 2(22)(e) of the Act does not apply. It is, however, in view of the clear position of law explained in Abhisar Buildwell Pvt. Ltd. (supra),not necessary to travel

THE ACIT, KOZHIKODE vs. SHRI K.C.JAMES, GOA

In the result, the Revenue’s appeals and the assessee’s COs are dismissed

ITA 54/COCH/2022[2013-14]Status: DisposedITAT Cochin31 Jul 2023AY 2013-14

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Surendranath Rao, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132ASection 143(3)Section 153ASection 2(22)(e)Section 2(45)

deemed dividend, rejecting the assessee’s explanation, since accepted by the ld. CIT(A), that the same is a trade advance/s, to which therefore the provision of sec. 2(22)(e) of the Act does not apply. It is, however, in view of the clear position of law explained in Abhisar Buildwell Pvt. Ltd. (supra),not necessary to travel