SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

In the result, the assessee’s appeal is partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

1)(c) of the Act vide notice u/s. 274 of even date: 2 Prakash R. Nair v. Dy.CIT, Central Circle i. Claim for deduction u/s 80IA(Rs.68,82,867/-) was rejected. ii. Bank interest of Rs. 3,13,508/- was assessed as ‘Income from Other Sources’. iii. The claim for deduction u/s 80HHC was restricted with reference to section 801A

APPLEXUS TECHNOLOGIES PRIVATE LIMITED,TRIVANDRUM vs. DCIT, KOTTAYAM

1: Incorrect rejection of the transfer pricing documentation prepared by the Assessee Ground No 1.1. The TPO AO has erred in disregarding the economic analysis carried out by the Assessee in the Transfer Pricing documentation (TP documentation") and rejecting the same Ground No 1.2: The TPO/AO has erred in computing the transfer pricing adjustment of the entity level by incorrectly

SRI. ELDHOSE K. VARGHESE,MUVATTUPUZHA vs. THEDCIT, ERNAKULAM

In the result, appeals for assessment year 2006-07 to 2008-09 and 2010-11 are allowed while the appeals of the assessee for assessment year 2009-10, 2011-12 and 2012-13 are partly allowed

Bench: Shri P. K. Bansal & Shri George George K.

c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person of such assessment year in the manner provided

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

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

13,172/- with its Associated Enterprises. The case of the Assessee was referred to the Transfer Pricing Officer (TPO) under Section 92CA of the Act for determination of the Arm's Length Price (ALP) in relation to the said international transactions. TPO passed order, dated 28/10/2016, under Section 92CA(3) of the Act proposing an upward transfer pricing adjustment

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

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

Transfer Pricing) (,TPO'), inter alia, since the TPO has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

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

Transfer Pricing) (,TPO'), inter alia, since the TPO has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

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

transfer pricing addition of Rs. 9,57,364/- to the income of the Assessee and holding that the international transactions pertaining to provision of corporate IT services do not satisfy the arm's length principle envisaged under the Act. 12.3 On the facts and in the circumstances of the case and in law, the Ld. AO/Ld. ΤΡΟ grossly erred

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. JCIT, RANGE-1, THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

transferred to Depositor Education and Awareness Fund. 5. On the facts and in the circumstances of the case and in law, the Id. CIT(A) erred in confirming the order of AO on classification of rural branches for section 36(1) (viia) based on population of village instead of population of ward. The South Indian Bank Ltd. 6. Without prejudice

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. ACIT, CIRCLE-1(1), THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

transferred to Depositor Education and Awareness Fund. 5. On the facts and in the circumstances of the case and in law, the Id. CIT(A) erred in confirming the order of AO on classification of rural branches for section 36(1) (viia) based on population of village instead of population of ward. The South Indian Bank Ltd. 6. Without prejudice

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. JCIT, CIRCLE-1(1), THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

transferred to Depositor Education and Awareness Fund. 5. On the facts and in the circumstances of the case and in law, the Id. CIT(A) erred in confirming the order of AO on classification of rural branches for section 36(1) (viia) based on population of village instead of population of ward. The South Indian Bank Ltd. 6. Without prejudice

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. ACIT, CIRCLE 1(1)& TPS, THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

transferred to Depositor Education and Awareness Fund. 5. On the facts and in the circumstances of the case and in law, the Id. CIT(A) erred in confirming the order of AO on classification of rural branches for section 36(1) (viia) based on population of village instead of population of ward. The South Indian Bank Ltd. 6. Without prejudice

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. DCIT, THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

transferred to Depositor Education and Awareness Fund. 5. On the facts and in the circumstances of the case and in law, the Id. CIT(A) erred in confirming the order of AO on classification of rural branches for section 36(1) (viia) based on population of village instead of population of ward. The South Indian Bank Ltd. 6. Without prejudice

THE SOUTH INDIAN BANK LIMITED ,THRISSUR vs. ACIT, CIRCLE 1(1), THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

transferred to Depositor Education and Awareness Fund. 5. On the facts and in the circumstances of the case and in law, the Id. CIT(A) erred in confirming the order of AO on classification of rural branches for section 36(1) (viia) based on population of village instead of population of ward. The South Indian Bank Ltd. 6. Without prejudice

M/S ASPINWALL & CO.,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

price relating to the buildings, I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 Plant and Machinery etc. belonging to an estate is never allowed as a revenue expenditure and it is not right on the part of the assessee to categorize the cost of acquisition of a thing as a revenue expenditure and the thing, as a capital asset. Therefore

THE DCIT, COCHIN vs. M/S.ASPINWALL & CO. LTD, COCHIN

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

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

price relating to the buildings, I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 Plant and Machinery etc. belonging to an estate is never allowed as a revenue expenditure and it is not right on the part of the assessee to categorize the cost of acquisition of a thing as a revenue expenditure and the thing, as a capital asset. Therefore

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

price relating to the buildings, I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 Plant and Machinery etc. belonging to an estate is never allowed as a revenue expenditure and it is not right on the part of the assessee to categorize the cost of acquisition of a thing as a revenue expenditure and the thing, as a capital asset. Therefore

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

price relating to the buildings, I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 Plant and Machinery etc. belonging to an estate is never allowed as a revenue expenditure and it is not right on the part of the assessee to categorize the cost of acquisition of a thing as a revenue expenditure and the thing, as a capital asset. Therefore

THE ACIT, CIRCLE-1, KOLLAM vs. M/S.OLAM AGRO INDIA P. LTD, KOLLAM

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

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year: 2013-14

transfer pricing adjustments. 4. Against this, the Revenue is in appeal before us. The Revenue has relied on the grounds raised. I.T.A. No.560/Coch/2019 5. The Ld. AR submitted that the assessment was bad in law as no draft assessment order was given to the assessee in violation of provisions contained in section 144C of the I.T. Act and, therefore