ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

reassessment where the same is sought to be initiated beyond 4 years of the relevant assessment year. It would be, to our mind, wholly incorrect to, in determining true and full disclosure, be guided by and, in any case, guided solely by the procedure prescribed by the relevant deduction provision, being s. 35(2AB) r/w r. 6 in the instant

ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

reassessment where the same is sought to be initiated beyond 4 years of the relevant assessment year. It would be, to our mind, wholly incorrect to, in determining true and full disclosure, be guided by and, in any case, guided solely by the procedure prescribed by the relevant deduction provision, being s. 35(2AB) r/w r. 6 in the instant

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,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

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

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)

35 Taxmann.com 456/258 CTR 454.’ (emphasis and notation, ours) 3.2 We firstly observe absence of any factual basis for the assessee to raise this legal ground. This is as vide his letter/s dated 21/3/2019 in penalty proceedings (PB pgs. 120-123), the assessee admits to have surrendered his income u/s. 69A, removing the factual basis for assuming the legal stance

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)

35 Taxmann.com 456/258 CTR 454.’ (emphasis and notation, ours) 3.2 We firstly observe absence of any factual basis for the assessee to raise this legal ground. This is as vide his letter/s dated 21/3/2019 in penalty proceedings (PB pgs. 120-123), the assessee admits to have surrendered his income u/s. 69A, removing the factual basis for assuming the legal stance

VALSAN CHIYYABATH,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

35 taxmann.com 435 and Hon'ble Madras High Court in the case of Dharampal R. Pandia v. DCIT 2021 MAD 917 confirmed levy of penalty u/s. 271(1)(c) of the Act. 6. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 7. When the appeal was called on nobody appeared on behalf

VALSAN CHIYYABATH NARAYANAN,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

35 taxmann.com 435 and Hon'ble Madras High Court in the case of Dharampal R. Pandia v. DCIT 2021 MAD 917 confirmed levy of penalty u/s. 271(1)(c) of the Act. 6. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 7. When the appeal was called on nobody appeared on behalf

VALSAN CHIYYABATH NARAYANAN,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

35 taxmann.com 435 and Hon'ble Madras High Court in the case of Dharampal R. Pandia v. DCIT 2021 MAD 917 confirmed levy of penalty u/s. 271(1)(c) of the Act. 6. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 7. When the appeal was called on nobody appeared on behalf

VALSAN CHIYYABATH NARAYANAN,THRISSUR vs. DCIT CIRCLE 1(1)& TPS, THRISSUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

35 taxmann.com 435 and Hon'ble Madras High Court in the case of Dharampal R. Pandia v. DCIT 2021 MAD 917 confirmed levy of penalty u/s. 271(1)(c) of the Act. 6. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 7. When the appeal was called on nobody appeared on behalf

KINGS INFRA VENTURES LTD,THEVARA vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1 (2), KOCHI, KOCHI

In the result, the appeal by the assessee is dismissed

Bench: Shri Sanjay Arora & Shri Sandeep Gosainkings Infra Ventures Ltd. Asstt. Commissioner Of A-1, 1St Floor, Atria Apartment Income Tax, Opp. Gurudwara Temple Vs. Circle - 1(2) Perumanur Road Kochi Thevara, Kochi [Pan:Aaccv3411D] (Respondent) (Appellant) Appellant By: Shri Joseph Markose, Sr. Advocate Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R.

35,85,037, i.e., without allowing any claim qua unabsorbed business loss or depreciation. In appeal, the ld. CIT(A) upheld the same in principle, holding as under after a detailed discussion on the various aspects of the matter, allowing part relief: “7. In sum, the Appeal for the impugned A.Y. 2011-12 is partly allowed. The amounts of unabsorbed

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