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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

36 (1)(vii) of the Act amounting to Rs 257.91 crores. The Ld.CIT(A) erred in appreciating the facts and settled legal position in this regard. The Ld. CIT (A) ought to have noted that the issue is squarely covered by the judicial decisions relied on by the appellant in this regard. 3 ITA Nos.393-399/Coch/2023. Federal Bank Limited

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

36 (1)(vii) of the Act amounting to Rs 257.91 crores. The Ld.CIT(A) erred in appreciating the facts and settled legal position in this regard. The Ld. CIT (A) ought to have noted that the issue is squarely covered by the judicial decisions relied on by the appellant in this regard. 3 ITA Nos.393-399/Coch/2023. Federal Bank Limited

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

36 (1)(vii) of the Act amounting to Rs 257.91 crores. The Ld.CIT(A) erred in appreciating the facts and settled legal position in this regard. The Ld. CIT (A) ought to have noted that the issue is squarely covered by the judicial decisions relied on by the appellant in this regard. 3 ITA Nos.393-399/Coch/2023. Federal Bank Limited

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

36 (1)(vii) of the Act amounting to Rs 257.91 crores. The Ld.CIT(A) erred in appreciating the facts and settled legal position in this regard. The Ld. CIT (A) ought to have noted that the issue is squarely covered by the judicial decisions relied on by the appellant in this regard. 3 ITA Nos.393-399/Coch/2023. Federal Bank Limited

AROOR CO-OP URBAN SOCIETY LTD,KOZHIKKODE vs. ITO, KOZHIKKODE

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

Bench: Shrigeorge George K.And Shrilaxmi Prasad Sahuaroor Co-Operative Urbn Society Dcit, Central Prossing Centre Aroor P.O., Kakkattil 673507 Bangalore Vs.

68 taxmann.com 298). He has submitted a copy of the P&L account in Annexure-2 which reads as follows: - S.No. Loss Rs. S.No. Profit Rs. 1 Total loss as per 1 Total profit as per trading account trading account 2 Interest 7359077 2 Interest receivable 5978097 outstanding 3 Establishment 1304782 3 expenses 4 Contingency 1231087 4 Miscellaneous 4242442 expenses

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

M/S.IBS SOFTWARE SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

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

Section 36(1)(iii) of the Act of 2 Assessment Year 2013-2014 INR.12,68,911/- The Assessee has now preferred the present appeal challenging Final Assessment Order. The Assessee has raised 17 Grounds of Appeal which are taken up in seriatim hereinafter. Ground No.1 3. Ground No.1 raised by the Assessee reads as under: “1. That the order

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

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

36) The said principle on which the penalty under section 271C was avoided, would also not apply in the present case. In the circumstances, we are not convinced that there could be any remand, by the Tribunal, as has been made by the Honourable Supreme Court in Eli Lilly (supra). 8. ITA No.606/Coch/2010 & Ors. 8 M/s.Jeevan Telecasting Corporation

THE ITO, TRIVANDRUM vs. M/S.PERRORKADA SERVICE CO-OP BANK LTD, TRIVANDRUM

In the result, the appeal of the Revenue in I

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

ii) Whether on the facts and circumstances of the case, the order of CIT(A) is correct in considering the fact that reserve/provision is neither actual expenses nor ascertain liability and not entitled to deduction u/s. 80P(2)? (iii) Whether on the facts and in the circumstances of the case, the order of the CIT(A) is correct