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

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

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

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

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

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

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

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

E R Per: Inturi Rama Rao, AM These appeals filed by the assessee are directed against the common order of the Commissioner of Income Tax (Appeals)-3, Kohi [CIT(A)] dated 25.10.2021 for Assessment Years (AY) 2012- 13 to 2016-17. 2. Since identical issues and facts are involved in these appeals, they are heard together and disposed

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

E R Per: Inturi Rama Rao, AM These appeals filed by the assessee are directed against the common order of the Commissioner of Income Tax (Appeals)-3, Kohi [CIT(A)] dated 25.10.2021 for Assessment Years (AY) 2012- 13 to 2016-17. 2. Since identical issues and facts are involved in these appeals, they are heard together and disposed