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

KOOTHERY NARAYANAN VIJAYAN,PALAKKAD vs. ITO, NON COP WARD 2(4) & TPS, COCHIN

In the result, all the captioned appeals and corresponding stay applications are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

reassessment proceedings, resulting in ex parte ITA Nos. 134 to 137 & 138/Coch/2025 & SA Nos. 19 to 22 & 23/Coch/2025 Koothery Narayanan Vijayan assessments. Even during penalty appeal proceedings, the assessee remained non-compliant, except for filing an additional ground much later challenging the jurisdiction of the AO. The assessee contended that the penalty was without jurisdiction as per the Act. However

KOOTHERY NARAYANAN VIJAYAN,PALAKKAD vs. ITO, NON COP WARD 2(4) & TPS, COCHIN

In the result, all the captioned appeals and corresponding stay applications are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

reassessment proceedings, resulting in ex parte ITA Nos. 134 to 137 & 138/Coch/2025 & SA Nos. 19 to 22 & 23/Coch/2025 Koothery Narayanan Vijayan assessments. Even during penalty appeal proceedings, the assessee remained non-compliant, except for filing an additional ground much later challenging the jurisdiction of the AO. The assessee contended that the penalty was without jurisdiction as per the Act. However

KOOTHERY NARAYANAN VIJAYAN,PALAKKAD vs. ITO, NON COP WARD 2(4) & TPS, COCHIN

In the result, all the captioned appeals and corresponding stay applications are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

reassessment proceedings, resulting in ex parte ITA Nos. 134 to 137 & 138/Coch/2025 & SA Nos. 19 to 22 & 23/Coch/2025 Koothery Narayanan Vijayan assessments. Even during penalty appeal proceedings, the assessee remained non-compliant, except for filing an additional ground much later challenging the jurisdiction of the AO. The assessee contended that the penalty was without jurisdiction as per the Act. However

KOOTHERY NARAYANAN VIJAYAN,PALAKKAD vs. ITO, NON COP WARD 2(4) & TPS, COCHIN

In the result, all the captioned appeals and corresponding stay applications are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

reassessment proceedings, resulting in ex parte ITA Nos. 134 to 137 & 138/Coch/2025 & SA Nos. 19 to 22 & 23/Coch/2025 Koothery Narayanan Vijayan assessments. Even during penalty appeal proceedings, the assessee remained non-compliant, except for filing an additional ground much later challenging the jurisdiction of the AO. The assessee contended that the penalty was without jurisdiction as per the Act. However

KOOTHERY NARAYANAN VIJAYAN,PALAKKAD vs. ITO, NON COP WARD 2(4) & TPS, COCHIN

In the result, all the captioned appeals and corresponding stay applications are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

reassessment proceedings, resulting in ex parte ITA Nos. 134 to 137 & 138/Coch/2025 & SA Nos. 19 to 22 & 23/Coch/2025 Koothery Narayanan Vijayan assessments. Even during penalty appeal proceedings, the assessee remained non-compliant, except for filing an additional ground much later challenging the jurisdiction of the AO. The assessee contended that the penalty was without jurisdiction as per the Act. However

SRI UKKANDATH DILEEPAN,UROOB NAGAR, PALAPRAM vs. ACIT(OSD)INTERNATIONAL TAXATION, KOZHIKODE

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

reassessment proceedings initiated in 3 ITA Nos.99-101/Coch/2024 Sri.Ukkandath Dileepan. his case. The appellant has challenged the issue of notice u/s 148 by the ITO, Ward-4, Tirur as lacking jurisdiction since the appellant was a non-resident. However, as discussed by the AO in the impugned order, the PAN jurisdiction of the appellant based on his local address was with

UKKANDATH DILEEPAN,PALLAPURAM vs. ITO INTERNATIONAL TAXATION, CALICUT

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

reassessment proceedings initiated in 3 ITA Nos.99-101/Coch/2024 Sri.Ukkandath Dileepan. his case. The appellant has challenged the issue of notice u/s 148 by the ITO, Ward-4, Tirur as lacking jurisdiction since the appellant was a non-resident. However, as discussed by the AO in the impugned order, the PAN jurisdiction of the appellant based on his local address was with

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

SRI SRAVAN KUMAR NEELA,NALGONDA vs. ACIT CENTRAL CIRCLE 1, KOZHIKODE

In the result, the instant appeals by the assesses are dismissed

Bench: Shri Sanjay Arora & Shri Manomohan Dasuma Maheshwara Rao Chinni Asst. Cit, Central Circle -1, Hno. 7-298, 7 Ward Aayakar Bhavan (North Block) Gandhi Bomma Centre Vs. Kozhikode 673001 Dachepalle, Guntur 522414 [Pan:Arjpc0342D] (Appellant) (Respondent)

124 ITR 40 (SC), held that loss on account of confiscation by the Customs Department was an allowable business loss. This did not find favour with the Apex Court, which held that the same could not be allowed either as a business loss or business expenditure; the former being subsumed ITA No. 895, 899/Coch/2022 (AY : 2017-18) Uma Maheshwara

SRI UMA MAHESHWARA RAO CHINNI,GUNTUR vs. ASST COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-1, KOZHIKODE

In the result, the instant appeals by the assesses are dismissed

Bench: Shri Sanjay Arora & Shri Manomohan Dasuma Maheshwara Rao Chinni Asst. Cit, Central Circle -1, Hno. 7-298, 7 Ward Aayakar Bhavan (North Block) Gandhi Bomma Centre Vs. Kozhikode 673001 Dachepalle, Guntur 522414 [Pan:Arjpc0342D] (Appellant) (Respondent)

124 ITR 40 (SC), held that loss on account of confiscation by the Customs Department was an allowable business loss. This did not find favour with the Apex Court, which held that the same could not be allowed either as a business loss or business expenditure; the former being subsumed ITA No. 895, 899/Coch/2022 (AY : 2017-18) Uma Maheshwara