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)

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment as referred to in sub-section (1), as the case may be. 3.2 Section 234B of the Act provides for levy of interest on the shortfall in advance tax, reckoned with reference

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.JOHN MATHEW N,ALAPPUZHA vs. THE ITO, WD-2, ALAPPUZHA, ALAPPUZHA

In the result, the appeal by the assessee is dismissed

Bench: Shri Sanjay Arora & Shri Sandeep Gosainshri John Mathew N. The Income Tax Officer Neroth House Ward - 2, Alleppey Vs. No. 1, Jubilee Road Alappuzha [Pan: Acupm8885D] Appellant Respondent Appellant By: Shri Anil D. Nair & Shri P.K. Biju, Advocates Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R. Date Of Hearing: 03.02.2023 Date Of Pronouncement: 24.02.2023 O R D E R Per Bench This Appeal By The Assessee Challenges The Validity Of The Reassessment Under Section 147 Read With Section 143(3) Of The Income Tax Act, 1961 (‘The Act’ Hereinafter) Dated 20.11.2007 For Assessment Year (Ay) 2001-02, Since Upheld In First Appeal Vide Order Dated 24.01.2018 By The Commissioner Of Income Tax (Appeals), Kottayam (‘Cit(A)’ For Short). 2.1 At The Outset, Shri Anil D. Nair, The Ld. Counsel For The Assessee-Appellant, Would Submit That The Basis Of The Assessee’S Challenge Is Two-Fold: (A) Non-Supply Of The Reasons Recorded; & (B) True & Full Disclosure Of All Material Facts Relating To The Income Escaping Assessment By The Assessee Per His Return Of Income.

reassessment under section 147 read with section 143(3) of the Income Tax Act, 1961 (‘the Act’ hereinafter) dated 20.11.2007 for assessment year (AY) 2001-02, since upheld in first appeal vide Order dated 24.01.2018 by the Commissioner of Income Tax (Appeals), Kottayam (‘CIT(A)’ for short). 2.1 At the outset, Shri Anil D. Nair, the ld. counsel

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

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

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

reassessment was completed vide order dated 28.03.2013 passed u/s. 143(3) r.w.s. 147 of the Act after making addition of Rs. 7,33,77,497/- being the amount paid to Muthoot Pappachan Consultancy & Management (hereinafter called “MPCMS”) towards professional charges/consultancy u/s. 40(a)(ia) for non-deduction of TDS. On further appeal before the CIT(A), the CIT(A) confirmed

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

reassessment was completed vide order dated 28.03.2013 passed u/s. 143(3) r.w.s. 147 of the Act after making addition of Rs. 7,33,77,497/- being the amount paid to Muthoot Pappachan Consultancy & Management (hereinafter called “MPCMS”) towards professional charges/consultancy u/s. 40(a)(ia) for non-deduction of TDS. On further appeal before the CIT(A), the CIT(A) confirmed

MUTHOOT FINCORP LIMITED,TRIVANDRUM vs. ITO,CIRCLE CENTRAL, TRIVANDRUM

In the result, the appeals filed by the assessee stand dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

reassessment was completed vide order dated 28.03.2013 passed u/s. 143(3) r.w.s. 147 of the Act after making addition of Rs. 7,33,77,497/- being the amount paid to Muthoot Pappachan Consultancy & Management (hereinafter called “MPCMS”) towards professional charges/consultancy u/s. 40(a)(ia) for non-deduction of TDS. On further appeal before the CIT(A), the CIT(A) confirmed