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

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

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

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

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

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

JUBILEE MISSION HOSPITAL,THRISSUR vs. THE DCIT, THRISSUR

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

20,12/986/- resulting in a overnight increase of Rs.64,22,411/-. Since Income chargeable to tax amounting to Rs.62,44,411/- has escaped assessment within the meaning of section 147 of the Income Tax Act 1961, the notice u/s 148 was issued.” 9. The contention of the Ld. A.R. is that the reasons recorded very clearly show that, the only

JUBILEE MISSION HOSPITAL,THRISSUR vs. THE DCIT, KOCHI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

20,12/986/- resulting in a overnight increase of Rs.64,22,411/-. Since Income chargeable to tax amounting to Rs.62,44,411/- has escaped assessment within the meaning of section 147 of the Income Tax Act 1961, the notice u/s 148 was issued.” 9. The contention of the Ld. A.R. is that the reasons recorded very clearly show that, the only

JUBILEE MISSION HOSPITAL ,KAKKANAD vs. THE DCIT, KOCHI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

20,12/986/- resulting in a overnight increase of Rs.64,22,411/-. Since Income chargeable to tax amounting to Rs.62,44,411/- has escaped assessment within the meaning of section 147 of the Income Tax Act 1961, the notice u/s 148 was issued.” 9. The contention of the Ld. A.R. is that the reasons recorded very clearly show that, the only

JUBILEE MISSION HOSPITAL.,THRISSUR vs. THE DCIT, KOCHI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

20,12/986/- resulting in a overnight increase of Rs.64,22,411/-. Since Income chargeable to tax amounting to Rs.62,44,411/- has escaped assessment within the meaning of section 147 of the Income Tax Act 1961, the notice u/s 148 was issued.” 9. The contention of the Ld. A.R. is that the reasons recorded very clearly show that, the only

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

10 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020 Asst. CIT vs. Apollo Tyres Ltd. Sure, the assessee was constrained for want of Form 3CL at the time of filing it’s return of income. What, however, we wonder, prevented it from stating so in the computation of income (copy on record), i.e., that

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

10 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020 Asst. CIT vs. Apollo Tyres Ltd. Sure, the assessee was constrained for want of Form 3CL at the time of filing it’s return of income. What, however, we wonder, prevented it from stating so in the computation of income (copy on record), i.e., that

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

10. Ground 3 is with regard to addition of Rs.57 lakhs. The facts show that assessee has developed a software inhouse by the name ‘Quadra’ software which is used in building construction by builders & real estate developers. Assessee developed it ‘ in – house’ and expenditure for such development was recovered from the customer for whom it was developed. AS the software

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

10. Ground 3 is with regard to addition of Rs.57 lakhs. The facts show that assessee has developed a software inhouse by the name ‘Quadra’ software which is used in building construction by builders & real estate developers. Assessee developed it ‘ in – house’ and expenditure for such development was recovered from the customer for whom it was developed. AS the software

PARISONS ESTATES AND INDUSTRIES PRIVATE LIMITED,CALICUT vs. ACIT CIRCLE 1(1), KOZHIKODE

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

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2009-10

147 of the Act. Further, as rightly stated by the Ld.CIT(A), there was no assessment u/s. 143(3) of the Act and therefore the question of new materials available for making the reassessment is not arisen in the present case. We, therefore, accepted that the reopening made by the AO is in order. 9. The assessee is having

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)

u/s 115 JB of the Act does not permit this as deduction. 3.4. Further this is actually provision claimed as bad debt by Vijaya Bank decision not accepted by Hon'ble Kerala high Court itself as the same issue was set aside to the Hon'ble ITAT to examine whether provision can be treated ad bad debts wrote

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