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

E R Per George George K., JM This appeal at the instance of the assessee is directed against Commissioner of Income-tax’s order dated 27.03.2017. The relevant assessment year is 2009-2010. 2. The solitary issue that was argued, was whether order passed u/s 263 of the Income-tax Act, 1961 was barred by limitation? 3. Brief facts

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

In the result, appeal filed by the assessee stands allowed

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

section 2(22)(e) of the Act have no application placing reliance on the decision of the Hon'ble Delhi High Court in the case of CIT vs. Creative Dyeing and Printing (P) ltd 318 ITR 476 (Delhi). The said contention was rejected by the AO and proceeded to hold that the transaction is in the nature of deemed dividend

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

In the result, appeal filed by the assessee stands allowed

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

section 2(22)(e) of the Act have no application placing reliance on the decision of the Hon'ble Delhi High Court in the case of CIT vs. Creative Dyeing and Printing (P) ltd 318 ITR 476 (Delhi). The said contention was rejected by the AO and proceeded to hold that the transaction is in the nature of deemed dividend

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

In the result, appeal filed by the assessee stands allowed

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

section 2(22)(e) of the Act have no application placing reliance on the decision of the Hon'ble Delhi High Court in the case of CIT vs. Creative Dyeing and Printing (P) ltd 318 ITR 476 (Delhi). The said contention was rejected by the AO and proceeded to hold that the transaction is in the nature of deemed dividend

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

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

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)

reassessment may be made shall apply to a re-assessment made under section 27 or to an assessment or re-assessment made on the assessee or any person in consequence of or to give effect to any finding or direction contained in an order under section 31, section 33, section 33-A, section 33-B, section 66 or section

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.

22,55,33,892 of Appellant and his family members 4. Alleged on-money paid in cash or ---- 16,10,00,000 16,10,00,000 acquisition of land / properties by family members Total Addition 34,01,94,057 2,75,19,40,663 3,09,21,34,720 3.18 Finally, the assessments were framed in similar fashion

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.

22,55,33,892 of Appellant and his family members 4. Alleged on-money paid in cash or ---- 16,10,00,000 16,10,00,000 acquisition of land / properties by family members Total Addition 34,01,94,057 2,75,19,40,663 3,09,21,34,720 3.18 Finally, the assessments were framed in similar fashion

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.

22,55,33,892 of Appellant and his family members 4. Alleged on-money paid in cash or ---- 16,10,00,000 16,10,00,000 acquisition of land / properties by family members Total Addition 34,01,94,057 2,75,19,40,663 3,09,21,34,720 3.18 Finally, the assessments were framed in similar fashion

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.

22,55,33,892 of Appellant and his family members 4. Alleged on-money paid in cash or ---- 16,10,00,000 16,10,00,000 acquisition of land / properties by family members Total Addition 34,01,94,057 2,75,19,40,663 3,09,21,34,720 3.18 Finally, the assessments were framed in similar fashion

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.

22,55,33,892 of Appellant and his family members 4. Alleged on-money paid in cash or ---- 16,10,00,000 16,10,00,000 acquisition of land / properties by family members Total Addition 34,01,94,057 2,75,19,40,663 3,09,21,34,720 3.18 Finally, the assessments were framed in similar fashion

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.

22,55,33,892 of Appellant and his family members 4. Alleged on-money paid in cash or ---- 16,10,00,000 16,10,00,000 acquisition of land / properties by family members Total Addition 34,01,94,057 2,75,19,40,663 3,09,21,34,720 3.18 Finally, the assessments were framed in similar fashion

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.

22,55,33,892 of Appellant and his family members 4. Alleged on-money paid in cash or ---- 16,10,00,000 16,10,00,000 acquisition of land / properties by family members Total Addition 34,01,94,057 2,75,19,40,663 3,09,21,34,720 3.18 Finally, the assessments were framed in similar fashion

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

E R Per George George K., JM This appeal at the instance of the assessee is directed against CIT’s order dated 22.12.2016 passed u/s 263 of the Income-tax Act, 1961. The relevant assessment year is 2010- 2011. 2. The grounds raised read as follows:- “1. The Commissioner of Income Tax (Exemptions), Kochi has vide order under section

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)

E R [ Per Rahul Chaudhary, Judicial Member: 1. The present appeal preferred by the Revenue is directed against the order, dated 25/03/2025, passed by National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘the NFAC’] under Section 250 of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] whereby the Ld. CIT(A) had partly allowed

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

E R Per Bench : These assessee’s seven appeals ITA Nos.393 to 399/Coch/2023 for the assessment years 2011-2012 to 2017-2018 arise against the CIT (Appeal) / NFAC, as many DIN & Order Nos.ITBA/NFAC/S/250/2022- 23/1051192560(1), 1051191040(1), 1051190237(1), 1051189723(1), 1051189258(1)1051187623(1) & 1051188629(1), all dated 23.03.2023, respectively, in proceedings u/s. 143(3) of the Income