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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

c)) The ld.CIT(A) ought to have noticed that the re-opening of assessment is done on the basis of change of opinion on same set of facts. The Ld. CIT(A) ought to have noticed that all the disallowances made in the assessment-u/s 144, section 36 (I)(vii) and 36 (I)(vii)) were only based

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

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

68,950 Total Rs.5,80,287 2005-06 Tax Rs.2,79,926 Tax Rs.4,15,203 As per schedule Interest Rs.96,719 Interest Rs.85,560 Total Rs.3,76,645 Total Rs.5,03,763 2006-07 Tax Rs.1,70,040 Tax Rs.1,70,040 As per schedule Interest Rs.85,560 Interest Rs.78,436 Total Rs.2,55,600 Total Rs.2

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

68,42,880/- towards Salary and other R&D expenses within the scope of "Fee for technical Services under explanation 2 of section 9(1)(vii)of Income Tax Act and liable for TDS. 5.2 The Ld AO erred in not appreciating that the assessee company has made payment of Rs 1,07,08,950/- for clinical trials majorly

INCOMETAX OFFICER, WARD-, KOTTAYAM vs. PUTHENKUDY PAULOSE BABU, KOTTAYAM

The appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

C P Fancy, Ward-1, Public Library vs. Goodwill Building, Shastry Building, Shastri Road, Road, Near Logos Junction, KOTTAYAM – 686 001. KOTTAYAM – 686 001. KERALA. PAN ASYPB3763D. KERALA. (Appellant) (Respondent) For Assessee : -None- For Revenue : Smt. V. Swarnalatha, Sr. DR Date of Hearing : 20.08.2024 Date of Pronouncement : 22.08.2024 ORDER PER SATBEER SINGH GODARA, J.M. This assessee’s appeal

M/S BEST BAKERY & ICE CREAM PARLOUR,ANGAMALLY vs. ACIT, ERNAKULAM

In the result, the appeals of the assessee in ITA Nos

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

251 ITR 1 (ITAT - Pune) [TM] and the decision of Allahabad ITAT in the case of RML Malhotra vs. ACIT 68 ITD 288 which was approved by Allahabad High Court reported in 186 Taxman 137) relied upon by the assessee with the argument that suppressed turnover can be brought to tax only for the period for which documents indicating

M/S. MATHA ENTERPRISES,,ANGAMALLY vs. ACIT, ERNAKULAM

In the result, the appeals of the assessee in ITA Nos

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

251 ITR 1 (ITAT - Pune) [TM] and the decision of Allahabad ITAT in the case of RML Malhotra vs. ACIT 68 ITD 288 which was approved by Allahabad High Court reported in 186 Taxman 137) relied upon by the assessee with the argument that suppressed turnover can be brought to tax only for the period for which documents indicating