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

68 of the Act. Further, it is pertinent to note that, unlike section 271(1)(c) of the Act, which requires the AO to record the satisfaction as regards various circumstances as dealt therein, no such requirement under the provisions of section 271AAC of the Act has been brought to our attention. 16. Therefore, in the present case

SRI.THOMAS EAPEN,ALAPPUZHA vs. THE ITO, WD-5, ALAPPUZHA

In the result, the appeal of the assessee is allowed

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

section 68 of the 27,94,306 Unexplained cash deposit in Act Bank 2. Undisclosed profit 3,14,953 Profit

SYEDALI EBRAHIM,THIRUVANANTHAPURAM vs. ITO WARD-1(1), THIRUVANANTHAPURAM

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

27,301/- under Section 68 of the Act; and (b) addition of INR.2,00,000/- by disallowing loss from

THE ACIT, ERNAKULAM vs. M/S. THOMSON METALS, TRICHUR

In the result, the appeal filed by the Revenue is allowed for statistical purposes

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

section 68 of the I.T.Act. When an assessee records credit in the name of third party in its books of account, it must prove not only the identity of the creditors, the capacity of the creditors to advance money, but also the genuineness of the transaction. The onus of proving ITA No.124/Coch/2017. 9 M/s.Thomson Metals. the source

THE ACIT, CEN-CIRCLE-2, ERNAKULAM, ERNAKULAM vs. M/S.THOMSON AGENCIES, THRISSUR

In the result, the appeals filed by the Revenue are allowed for statistical purposes

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

section leaves no doubt that the addition u/s 68 has to be made in the hands of the assessee in whose books the credits appear and not in the hands of the creditor of the assessee. 2. The CIT(A) in deciding that unexplained credits brought into the books of the firm by the partners need to considered

THE ACIT, CEN-CIRCLE-2, ERNAKULAM, ERNAKULAM vs. M/S.THOMSON AGENCIES, KOMBODINJAMAKKAL, TRICHUR, TRICHUR

In the result, the appeals filed by the Revenue are allowed for statistical purposes

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

section leaves no doubt that the addition u/s 68 has to be made in the hands of the assessee in whose books the credits appear and not in the hands of the creditor of the assessee. 2. The CIT(A) in deciding that unexplained credits brought into the books of the firm by the partners need to considered

THE ACIT, CEN-CIRCLE-2, ERNAKULAM, ERNAKULAM vs. M/S.THOMSON AGENCIES, TRICHUR

In the result, the appeals filed by the Revenue are allowed for statistical purposes

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

section leaves no doubt that the addition u/s 68 has to be made in the hands of the assessee in whose books the credits appear and not in the hands of the creditor of the assessee. 2. The CIT(A) in deciding that unexplained credits brought into the books of the firm by the partners need to considered

THE ACIT, CEN-CIRCLE-2, KOCHI, KOCHI vs. M/S.THOMSON AGENCIES, TRICHUR

In the result, the appeals filed by the Revenue are allowed for statistical purposes

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

section leaves no doubt that the addition u/s 68 has to be made in the hands of the assessee in whose books the credits appear and not in the hands of the creditor of the assessee. 2. The CIT(A) in deciding that unexplained credits brought into the books of the firm by the partners need to considered

THE ACIT, CEN-CIRCLE-2, ERNAKULAM, ERNAKULAM vs. M/S.THOMSON AGENCIES, TRICHUR

In the result, the appeals filed by the Revenue are allowed for statistical purposes

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

section leaves no doubt that the addition u/s 68 has to be made in the hands of the assessee in whose books the credits appear and not in the hands of the creditor of the assessee. 2. The CIT(A) in deciding that unexplained credits brought into the books of the firm by the partners need to considered

THE ACIT, CEN-CIRCLE-2, ERNAKULAM, ERNAKULAM vs. M/S.THOMSON AGENCIES, THRISSUR

In the result, the appeals filed by the Revenue are allowed for statistical purposes

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

section leaves no doubt that the addition u/s 68 has to be made in the hands of the assessee in whose books the credits appear and not in the hands of the creditor of the assessee. 2. The CIT(A) in deciding that unexplained credits brought into the books of the firm by the partners need to considered

THE ACIT, CEN-CIRCLE-2, ERNAKULAM, ERNAKULAM vs. M/S.THOMSON AGENCIES, TRICHUR

In the result, the appeals filed by the Revenue are allowed for statistical purposes

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

section leaves no doubt that the addition u/s 68 has to be made in the hands of the assessee in whose books the credits appear and not in the hands of the creditor of the assessee. 2. The CIT(A) in deciding that unexplained credits brought into the books of the firm by the partners need to considered

M/S SANTHIMADOM HERBAL CITY TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

27 days. An affidavit of even date by Dr. V.N. Radhakrishnan, Managing Trustee, explains the reasons leading to the same. The contents of the affidavit, carefully perused, cites reasons personal in nature. The same have not been disputed by the Revenue. Under the circumstances, we, accepting the assessee’s application for condonation of delay, admit the instant appeals. Hearing

M/S SANTHIMADOM HERBAL CITY TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are partly allowed

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

27 days. An affidavit of even date by Dr. V.N. Radhakrishnan, Managing Trustee, explains the reasons leading to the same. The contents of the affidavit, carefully perused, cites reasons personal in nature. The same have not been disputed by the Revenue. Under the circumstances, we, accepting the assessee’s application for condonation of delay, admit the instant appeals. Hearing

V.K.M FEEDS PRIVATE LIMITED,TAMILNADU vs. ACIT,CENTRAL CIRCLE, THRISSUR

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

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhailassessment Year : 2017-18 Vkm Feeds Private Limited, Acit, Central Circle, 2, Reservoir Street, Thrissur Venkatesa Colony, Vs. Pollachi-642001 Tamil Nadu Pan : Aafcv2454D (Appellant) (Respondent) For Assessee : Shri Shaji Paulose, Ca For Revenue : Shri Sanjit Kumar Das, Cit-Dr (Heard In Hybrid Bench) Date Of Hearing : 25-03-2025 Date Of Pronouncement : 27-05-2025

68 of the Act. 20. However, it is an undisputed fact that the statement recorded under Section 132(4) of the Act has better evidentiary value but it is also a settled position of law that addition cannot be sustained merely on the basis of the statement. There has to be some material corroborating the content of the statements

SUPRIYA ENTERPRISES,MANJERI, MALAPPURAM vs. THE ITO, TIRUR

Appeal is dismissed

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalm/S. Supriya Enterprises Principal Commissioner Of 16,263, Calicut Road Income Tax Vs. Manjeri, Malappuram 676121 Kozhikode

Section 263 of the Income Tax Act, 1961 (in short the Act). Heard both the parties. Case file perused. 2. We first of all note that PCIT’s impugned revision directions read as follows: - “1. The assessee filed the Return of Income for A.Y 2015-16 on 24-03-2017 admitting a total income

INCOME TAX OFFICER, THIRUVANANTHAPURAM vs. THIRUVANANTHAPURAM SERVICE CO-OPERATIVE BANK LTD, THIRUVANANTHAPURAM

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

27,30,080/- after making the addition of Rs.2,83,80,844/- under Section 40A(ia) for disallowance of expenses where TDS was not deducted. The assessee denied the status of the society as a co-operative society and consequently, treating interest income of Rs.2,95,38,828/- as income from other sources, thereby denying deduction under Section

KERALA GAZETTED OFFICERS CO-OPERATIVE SOCIETY LIMITED NO. T-424,TRIVANDRUM vs. THE INCOME TAX OFFICER, TRIVANDRUM

Appeal is partly allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhkerala Gazetted Officers The Income Tax Officer Co-Op. Society Ltd. Ward - 2(1), Trivandrum Vazhuthakkdu, Thycaud Post Vs. Trivandrum 695014 [Pan: Aacak6865C] (Appellant) (Respondent)

27,62,392/- 2) Having confirmed the business income as above, the Commissioner of Income Tax (Appeals) ought to have concluded therein only that the entire amount of 2 Kerala Gazetted Officers Co-op. Society Ltd. Rs.3.27,62,392/- is eligible for deduction u/s 80P(2)(a)(i), having held so elsewhere in the appellate order. 3) The learned Commissioner

SMT.K.B.SONY,COCHIN vs. THE DCIT, COCHIN

In the result, i) The appeal of the assessee in ITA No

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 36 deals with other deduction in respect of premium paid, interest etc. 3.7 In the present case, there is no allegation by the Assessing Officer that the sassessee has not incurred any expenditure. The only allegation is that the assessee has not rendered any services to M/s. Rosy Blue (India) Pvt. Ltd. In our opinion when there