REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

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

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

29] ■ The provisions of section 147 are analogous to provisions of section 153A. Section 147 deals with income escaping assessment, and as per the said provisions, if any income chargeable to tax in case of an assessee has escaped assessment for any assessment year, the Assessing Officer shall assess or reassess such income for such assessment year. Further, section

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

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

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

29] ■ The provisions of section 147 are analogous to provisions of section 153A. Section 147 deals with income escaping assessment, and as per the said provisions, if any income chargeable to tax in case of an assessee has escaped assessment for any assessment year, the Assessing Officer shall assess or reassess such income for such assessment year. Further, section

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

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

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

29] ■ The provisions of section 147 are analogous to provisions of section 153A. Section 147 deals with income escaping assessment, and as per the said provisions, if any income chargeable to tax in case of an assessee has escaped assessment for any assessment year, the Assessing Officer shall assess or reassess such income for such assessment year. Further, section

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

29]\n■ The provisions of section 147 are analogous to provisions of section 153A. Section\n147 deals with income escaping assessment, and as per the said provisions, if any\nincome chargeable to tax in case of an assessee has escaped assessment for any\n assessment year, the Assessing Officer shall assess or reassess such income for such\n assessment year

MARIAMMA JOSEPH,KOTTAYAMN vs. THE ACIT, CENTRAL CIRCLE, KOTTAYAM,, KOTTAYAM

In the result, the assessee’s appeal is decided on the aforesaid terms

Bench: Shri Sanjay Arora & Shri Manomohan Dasmariamma Joseph Asst. Cit, Central Circle Hotel Floral Park Kottayam 686001 Gandhinagar Vs. Kottayam 686008 [Pan:Accpj9135F] (Appellant) (Respondent)

10,84,900 on 13/10/2010, admitting tax liability of Rs. 2,28,114, stood processed, or deemed to be so, in October, 2010, or latest by March, 2012. Interest u/s. 234B(3), which is to be for the period following the date of processing up to the date of reassessment or, as Mariamma Joseph v. Asst. CIT, Central Circle

M.K RAJENDRAN PILLAI,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

Section 10(26) of the Act. Certain discrepancies and mismatch in signatures were noted in the loan confirmation letters obtained from loan creditors. The funds were also allegedly utilized for making payment to contractors, payment for civil work etc. for the group concerns. Some of the funds were transferred to bank accounts of family members, friends and relatives etc. whereas

M.K RAJENDRAN PILLAI,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

Section 10(26) of the Act. Certain discrepancies and mismatch in signatures were noted in the loan confirmation letters obtained from loan creditors. The funds were also allegedly utilized for making payment to contractors, payment for civil work etc. for the group concerns. Some of the funds were transferred to bank accounts of family members, friends and relatives etc. whereas

M.K RAJENDRAN PILLAI,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

Section 10(26) of the Act. Certain discrepancies and mismatch in signatures were noted in the loan confirmation letters obtained from loan creditors. The funds were also allegedly utilized for making payment to contractors, payment for civil work etc. for the group concerns. Some of the funds were transferred to bank accounts of family members, friends and relatives etc. whereas

M.K RAJENDRAN PILLAI,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

Section 10(26) of the Act. Certain discrepancies and mismatch in signatures were noted in the loan confirmation letters obtained from loan creditors. The funds were also allegedly utilized for making payment to contractors, payment for civil work etc. for the group concerns. Some of the funds were transferred to bank accounts of family members, friends and relatives etc. whereas

M.K RAJENDRAN PILLAI,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

Section 10(26) of the Act. Certain discrepancies and mismatch in signatures were noted in the loan confirmation letters obtained from loan creditors. The funds were also allegedly utilized for making payment to contractors, payment for civil work etc. for the group concerns. Some of the funds were transferred to bank accounts of family members, friends and relatives etc. whereas

M.K RAJENDRAN PILLAI,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

Section 10(26) of the Act. Certain discrepancies and mismatch in signatures were noted in the loan confirmation letters obtained from loan creditors. The funds were also allegedly utilized for making payment to contractors, payment for civil work etc. for the group concerns. Some of the funds were transferred to bank accounts of family members, friends and relatives etc. whereas

M.K RAJENDRAN PILLAI,PATHANAMTHITTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

Section 10(26) of the Act. Certain discrepancies and mismatch in signatures were noted in the loan confirmation letters obtained from loan creditors. The funds were also allegedly utilized for making payment to contractors, payment for civil work etc. for the group concerns. Some of the funds were transferred to bank accounts of family members, friends and relatives etc. whereas

DY.COMMISSIONER OF INCOME TAX, THRISSUR vs. THE CSB BANK LTD, THRISSUR

In the result, the appeal of revenue is dismissed

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of the Assessment Order, dated 28/07/2023, passed under Section 143(3) read with Section 147 of the Act making the following additions/disallowance: Addition of INR.38.24 Crores (under normal provisions): The (a) Assessing Officer observed that the as per the details of movement of NPA provisions furnished

INCOME TAX OFFICER, WARD 1 TPS, ALUVA, INCOME TAX OFFICE, ALUVA vs. CIJO JOSEPH, ANGAMALY

In the result, both the appeals of the revenue are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

reassessment order passed under section 143(3) read with section 263 pursuant to the directions of the PCIT in revisionary proceedings.Since the issues are interlinked, both appeals are heard together and disposed of by this common order. First we take up ITA No. 604/Coch/2024. 2. In both the appeals, there were delays of 29 days in filing the appeals

INCOME TAX OFFICER, WARD 1 TPS, ALUVA, INCOME TAX OFFICE, ALUVA vs. CIJO JOSEPH, ANGAMALY

In the result, both the appeals of the revenue are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

reassessment order passed under section 143(3) read with section 263 pursuant to the directions of the PCIT in revisionary proceedings.Since the issues are interlinked, both appeals are heard together and disposed of by this common order. First we take up ITA No. 604/Coch/2024. 2. In both the appeals, there were delays of 29 days in filing the appeals

ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

29 ITR 529 (SC)(also see: Lakshmiratan Cotton Mills Co. v. CIT [1969] 73 ITR 634 (SC). There can again be no quarrel on the proposition that the assessee can furnish only what is available with it, as surely law cannot impose an impossible burden. Page 10 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020

ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

29 ITR 529 (SC)(also see: Lakshmiratan Cotton Mills Co. v. CIT [1969] 73 ITR 634 (SC). There can again be no quarrel on the proposition that the assessee can furnish only what is available with it, as surely law cannot impose an impossible burden. Page 10 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020

SREEKUMARI AMMA,THIRUVANANTHAPURAM vs. DCIT, CENTRAL CIRCLE, THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

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

Bench: Smt. Beena Pillai & Ms. Padmavathy S

29,573 - 2016-17 2,80,137 - 2017-18 2,38,116 - 5. For A.Ys. 2016-17 and 2017-18, the Assessing Officer made addition towards agricultural income as income from other sources. Aggrieved by the order of the Assessing Officer, the assessee preferred further appeal before the CIT(A). The CIT(A) upheld the additions / disallowances made by Assessing

SREEKUMARI AMMA,THIRUVANANTHAPURAM vs. DCIT, CENTRAL CIRCLE, THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

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

Bench: Smt. Beena Pillai & Ms. Padmavathy S

29,573 - 2016-17 2,80,137 - 2017-18 2,38,116 - 5. For A.Ys. 2016-17 and 2017-18, the Assessing Officer made addition towards agricultural income as income from other sources. Aggrieved by the order of the Assessing Officer, the assessee preferred further appeal before the CIT(A). The CIT(A) upheld the additions / disallowances made by Assessing