M/S PAZHAYANGADI G GOLD,KANNUR vs. ITO WARD 1 & TPS, KANNUR

In the result, the appeal by the assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhailassessment Year : 2018-19 Pazhayangadi G Gold, Ito, Ward-1& Tps, Eazhome Pazhayangadi, Kannur Kannur-670303 Vs. Pan : Aaufp9485G (Appellant) (Respondent) For Assessee : Shri Arun Raj S. Adv. For Revenue : Shri Sanjit Kumar Das, Cit-Dr (Heard In Hybrid Bench) Date Of Hearing : 25-03-2025 Date Of Pronouncement : 27-05-2025 O R D E R

2) of the Act, which specifically prohibit the imposition of a penalty under section 270A of the Act in respect of additions, inter-alia, made under section 68 of the Act. Thus, we are of the considered view thatthe penalty proceedings under section 270A of the Act were rightly dropped by the AO. 12. As regards

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.

2) and 142(1) were issued on various occasions to the assessee requiring it to file requisite documents including cash flow statement and statement ITA Nos.580 to 586/Coch/2022 of assets and liabilities. The assessee’s case was centralized from Nagaland to Kerala which was challenged without any success before Hon’ble Guwahati High Court vide order dated 25.09.2019. Since

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.

2) and 142(1) were issued on various occasions to the assessee requiring it to file requisite documents including cash flow statement and statement ITA Nos.580 to 586/Coch/2022 of assets and liabilities. The assessee’s case was centralized from Nagaland to Kerala which was challenged without any success before Hon’ble Guwahati High Court vide order dated 25.09.2019. Since

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.

2) and 142(1) were issued on various occasions to the assessee requiring it to file requisite documents including cash flow statement and statement ITA Nos.580 to 586/Coch/2022 of assets and liabilities. The assessee’s case was centralized from Nagaland to Kerala which was challenged without any success before Hon’ble Guwahati High Court vide order dated 25.09.2019. Since

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.

2) and 142(1) were issued on various occasions to the assessee requiring it to file requisite documents including cash flow statement and statement ITA Nos.580 to 586/Coch/2022 of assets and liabilities. The assessee’s case was centralized from Nagaland to Kerala which was challenged without any success before Hon’ble Guwahati High Court vide order dated 25.09.2019. Since

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.

2) and 142(1) were issued on various occasions to the assessee requiring it to file requisite documents including cash flow statement and statement ITA Nos.580 to 586/Coch/2022 of assets and liabilities. The assessee’s case was centralized from Nagaland to Kerala which was challenged without any success before Hon’ble Guwahati High Court vide order dated 25.09.2019. Since

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.

2) and 142(1) were issued on various occasions to the assessee requiring it to file requisite documents including cash flow statement and statement ITA Nos.580 to 586/Coch/2022 of assets and liabilities. The assessee’s case was centralized from Nagaland to Kerala which was challenged without any success before Hon’ble Guwahati High Court vide order dated 25.09.2019. Since

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.

2) and 142(1) were issued on various occasions to the assessee requiring it to file requisite documents including cash flow statement and statement ITA Nos.580 to 586/Coch/2022 of assets and liabilities. The assessee’s case was centralized from Nagaland to Kerala which was challenged without any success before Hon’ble Guwahati High Court vide order dated 25.09.2019. Since

SREEPATHY TRUST,THRISSUR vs. CIT, CIRCLE 1, THRISSUR

In the result, both the captioned appeals are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

2) and 142(1) were issued, to which the assessee complied by furnishing certain details. During the reassessment proceedings, the Assessing Officer (AO) specifically asked the assessee to furnish complete details of persons from whom loans or advances had been received. This included names, addresses, dates, amounts, modes of receipt/payment, and bank statements. In response, the assessee submitted a list

SREEPATHY TRUST,THRISSUR vs. COMMISSIONER OF INCOME TAX CIRLE 1(1) , THRISSUR

In the result, both the captioned appeals are dismissed

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

2) and 142(1) were issued, to which the assessee complied by furnishing certain details. During the reassessment proceedings, the Assessing Officer (AO) specifically asked the assessee to furnish complete details of persons from whom loans or advances had been received. This included names, addresses, dates, amounts, modes of receipt/payment, and bank statements. In response, the assessee submitted a list

THE MANNUR SERVICE CO-OP BANK LTD,PALAKKAD vs. THE ITO WD-2, PALAKKAD

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

2 M/s.The Mannur SCB Limited. and proposed to complete the assessment u/s 144 of the I.T.Act. The Assessing Officer also proposed to deny deduction u/s 80P of the I.T.Act for the reason that primary object of the assessee was not fulfilled since the disbursement of agricultural loans for the year under consideration was only minuscule compared to the total loan

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed

KOODARANHI REGIONAL AGRICULTURAL WELFARE CO-OP SOCIETY LTD,KOZHIKKODE vs. THE ITO, KOZHIKKODE

In the result, the appeal by the assessee is allowed for statistical purposes and the stay petition is dismissed

Bench: Shri George George K. & Ms. Padmavathy S.

2) is allowable on merits as per the decision of the Hon’ble Supreme Court in the case of Mavilayil Service Coop. Bank Ltd. v. CIT [2021] 123 taxmann.com 161. The ld AR further submitted that the provisions contained in section 80AC of the Act as to the filing of return within the due date specified

VRINDAVAN BHAVAN PVT LTD,NAGALAND vs. ACIT CENTRAL CIRCLE, KOLLAM

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

2) and 142(3) of the Act. 3. That the Ld. CIT(A) has erred in upholding addition of Rs. 25,00,000/- made by the Ld. A.O on account of transfer made by P.S. Enterprise ignoring the submissions and evidences filed by the Appellant company. 4. That the Ld. CIT(A) has further erred in confirming the addition