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)

1). 4.8 The heads of income chargeable under the Act are classified u/s. 14. Section 14 starts with a saving clause "save as otherwise provided by this Act", which implies that there can be a class of income other than the classes of income specified u/s. 14, as provided under any other part of the Act. Sections 68

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

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1-4-2007. Subsequently Rule 8D was prescribed by the Government for the purpose of sub-section (2) of Section 14A from 2007-08 onwards. The Hon’ble Court observed that by virtue of the subsequent legislation, there was a 5 ITA Nos.393-399/Coch/2023. Federal Bank Limited. precise formula for working out the disallowance to be made under section

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1-4-2007. Subsequently Rule 8D was prescribed by the Government for the purpose of sub-section (2) of Section 14A from 2007-08 onwards. The Hon’ble Court observed that by virtue of the subsequent legislation, there was a 5 ITA Nos.393-399/Coch/2023. Federal Bank Limited. precise formula for working out the disallowance to be made under section

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1-4-2007. Subsequently Rule 8D was prescribed by the Government for the purpose of sub-section (2) of Section 14A from 2007-08 onwards. The Hon’ble Court observed that by virtue of the subsequent legislation, there was a 5 ITA Nos.393-399/Coch/2023. Federal Bank Limited. precise formula for working out the disallowance to be made under section

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1-4-2007. Subsequently Rule 8D was prescribed by the Government for the purpose of sub-section (2) of Section 14A from 2007-08 onwards. The Hon’ble Court observed that by virtue of the subsequent legislation, there was a 5 ITA Nos.393-399/Coch/2023. Federal Bank Limited. precise formula for working out the disallowance to be made under section

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1-4-2007. Subsequently Rule 8D was prescribed by the Government for the purpose of sub-section (2) of Section 14A from 2007-08 onwards. The Hon’ble Court observed that by virtue of the subsequent legislation, there was a 5 ITA Nos.393-399/Coch/2023. Federal Bank Limited. precise formula for working out the disallowance to be made under section

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

1-4-2007. Subsequently Rule 8D was prescribed by the Government for the purpose of sub-section (2) of Section 14A from 2007-08 onwards. The Hon’ble Court observed that by virtue of the subsequent legislation, there was a 5 ITA Nos.393-399/Coch/2023. Federal Bank Limited. precise formula for working out the disallowance to be made under section

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

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

section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink charges

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

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

68,481/-. Since assessee had huge interest bearing funds and investments were made in the mutual funds of sister concerns from where tax dividend was also earned, the I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 Assessing Officer disallowed interest amounting to Rs.18,43,500/- under section 14A r.w.r. 8D of the Income Tax Rules, 1962. 4. On appeal