THE CHOICE FOUNDATION,COCHIN vs. THE ACIT, COCHIN

In the result, appeal filed by the assessee is allowed

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

2) of the I.T.Act has to be reckoned from the date of assessment order and not from the date of reassessment when the issue raised in the revision u/s 263 of the I.T.Act was not subject matter of reassessment u/s 147 of the I.T.Act. The relevant observation of the Hon’ble Apex Court at para 15 of the judgment reads

M/S.US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE JCIT, TRIVANDRUM

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

2) of the I.T.Act would begin to run from the date of original order of assessment and not from the date of reassessment order. The relevant finding the Hon’ble Apex Court reads as follows:- (Para 15) “We, therefore, are clearly of the opinion that keeping in view the facts and circumstances of this case and, in particular, having regard

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

SRI. ELDHOSE K. VARGHESE,MUVATTUPUZHA vs. THEDCIT, ERNAKULAM

In the result, appeals for assessment year 2006-07 to 2008-09 and 2010-11 are allowed while the appeals of the assessee for assessment year 2009-10, 2011-12 and 2012-13 are partly allowed

Bench: Shri P. K. Bansal & Shri George George K.

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

M/S.POPULAR FINANCE,PATHANAMTHITTA vs. THE ACIT, CIRCLE-1, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

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

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section