MALANADU FARMERS SOCIETY ,KOTTAYAM vs. DCIT EXEMPTIONS, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

Bench: Shri George George K. & Ms. Padmavathy S.

143(1) of the Act in your case on 11/10/2019 shall not be treated as erroneous and be revised accordingly.” 4. The assessee filed a detailed reply dated 2.3.2022 (pg. 45 to 51 of PB) where the assessee submitted that the main object of the assessee is to protect small and marginal farmers and increase the living standards of farmers

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

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

143(3) read with Section 92CA read with Section 144C of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the directions issued by Dispute Resolution Panel - 2, Bangalore [for short ‘DRP’], on 07/08/2017 under Section 144C(5) of the Act. 2. The relevant facts in brief are that the Assessee is a subsidiary of International

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

PLANT LIPIDS (P) LTD.,KADAYIRUPPU vs. DCIT , CORPORATE CIRCLE-2(1), KOCHI

In the result appeal filed by assessee stands allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessmentyear:2020-21 Plant Lipids (P) Ltd. Kadayiruppu Po Kolenchery Dcit, Vs. Kerala 682 311 Corporate Circle-2(1) Kochi Pan No : Aabcp6061C Appellant Respondent Appellant By : Shri Thomson Thomas, A.R. Respondent By : Shri Sanjit Kumar Das, D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 O R D E R Perkeshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ao, Assessment Unit, Income Tax Department Dated 19.6.2024 Vide Din No.Itba/Ast/S/143(3)/2024- 25/1065876641(1) For The Ay 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”). 2. The Assessee Has Raised Following Grounds Of Appeal: Plant Lipids (P) Ltd., Kolencherry, Kerala Page 2 Of 8

Transfer Pricing Order made an adjustment of Rs.2,03,38,752/- towards notional guarantee commission in respect of corporate guarantee given by the assessee for its Subsidiary.After receiving the order of the TPO, the Assessing Officer made a draft assessment order u/s 144(1) proposing to make the following adjustments:- i. Addition as proposed by TPO — towards notional Guarantee Commission

M/S.JOY ALUKKAS INDIA P. LTD,COCHIN vs. THE ACIT, COCHIN

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

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

143(3) r.w.s. 144C(13) after proposing the following additions:- a) Addition by way of adjustments of Rs. 7,86,61,786/- b) Addition made on account of leasehold premises of Rs. 12,12,97,648/-. 4 IT (TP) A No. 119/Coch/2016 & IT (TP) A Nos. 38 & 643/Coch/2017 M/s. Joyalukkas India Pvt. Ltd. c) Addition on account of insurance claim

M/S.JOY ALUKKAS INDIA P. LTD,TRICHUR vs. THE ACIT, ERNAKULAM

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

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

143(3) r.w.s. 144C(13) after proposing the following additions:- a) Addition by way of adjustments of Rs. 7,86,61,786/- b) Addition made on account of leasehold premises of Rs. 12,12,97,648/-. 4 IT (TP) A No. 119/Coch/2016 & IT (TP) A Nos. 38 & 643/Coch/2017 M/s. Joyalukkas India Pvt. Ltd. c) Addition on account of insurance claim

MRS.REENA JOSE,PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE,, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

143(3) for the assessment year 2009-10 4 ITA Nos.207/Coch/2019 & Ors. Reena Jose & Ors. in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose, who were the heads of the respective trustee families. No assessments in consequence to search were made in relation to other family members who were trustees by invoking provisions

MRS.GRACY BABU,ADOOR P.O., PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

143(3) for the assessment year 2009-10 4 ITA Nos.207/Coch/2019 & Ors. Reena Jose & Ors. in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose, who were the heads of the respective trustee families. No assessments in consequence to search were made in relation to other family members who were trustees by invoking provisions

SRI.JOSE THOMAS,ADOOR P.O., PATHANAMTHITTA vs. THE ACIT,CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

143(3) for the assessment year 2009-10 4 ITA Nos.207/Coch/2019 & Ors. Reena Jose & Ors. in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose, who were the heads of the respective trustee families. No assessments in consequence to search were made in relation to other family members who were trustees by invoking provisions

SRI.JOSE THOMAS,ADOOR P.O., PATHANAMTHITTA vs. THE ACIT,CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

143(3) for the assessment year 2009-10 4 ITA Nos.207/Coch/2019 & Ors. Reena Jose & Ors. in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose, who were the heads of the respective trustee families. No assessments in consequence to search were made in relation to other family members who were trustees by invoking provisions

MRS.GRACY BABU,ADOOR P.O., PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

143(3) for the assessment year 2009-10 4 ITA Nos.207/Coch/2019 & Ors. Reena Jose & Ors. in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose, who were the heads of the respective trustee families. No assessments in consequence to search were made in relation to other family members who were trustees by invoking provisions

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)

143(1), i.e., as such, granting refund for Rs.18.62 lakhs, on 15.03.2002. Subsequently, on 16.04.2002, notice u/s. 148(1) was issued, which was responded to by filing a return of income on 06.06.2003 at Rs.19,30,992, i.e., at an increase of Rs.1,02,199, retaining deduction u/c. VI-A at Rs.4.15 crores, even as that u/s. 80HHC stands enhanced

THE ACIT CORPORATE, COCHIN vs. M/S.KERA FIBERTEX INTERNATIONAL P. LTD, COCHIN

In the result, the appeals by the assessee is allowed, and that by the Revenue, dismissed

Bench: Shri Sanjay Arora (Accountant Member), Shri Manomohan Das (Judicial Member)

143(3) of the Income Tax Act, 1961 (‘the Act’) dated 28.3.2013 for Assessment Year (AY) 2009-10. ITANos. 311 & 361/Coch/ 2015 (AY 2009-10) Kera Fibertex International P. Ltd. vs. Asst. CIT The background facts 2. At the very outset, it was observed by the Bench that the order dated 28.3.2013 on record, signifying the impugned assessment, is titled

M/S.KERA FIBERTEX INTERNATIONAL P. LTD,COCHIN vs. THE ACIT, COCHIN

In the result, the appeals by the assessee is allowed, and that by the Revenue, dismissed

Bench: Shri Sanjay Arora (Accountant Member), Shri Manomohan Das (Judicial Member)

143(3) of the Income Tax Act, 1961 (‘the Act’) dated 28.3.2013 for Assessment Year (AY) 2009-10. ITANos. 311 & 361/Coch/ 2015 (AY 2009-10) Kera Fibertex International P. Ltd. vs. Asst. CIT The background facts 2. At the very outset, it was observed by the Bench that the order dated 28.3.2013 on record, signifying the impugned assessment, is titled

APOLLO TYRES LTD.,COCHIN vs. DCIT CORPORATE CIR 1(1), KOCHI

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: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, 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: 10.09.2025

143(3) r.w.s., 144C(13) & 144B of the Income-tax Act, 1961 ('the Act') dated 20th June, 2024, by the Assessment Unit, Income Tax Department (AO') pursuant to the directions of the Dispute Resolution Panel ('DRP'), and the additions/disallowances made by the Id. AO/TPO, are grossly injudicious, unwarranted, against the facts of the case and bad in law. 2

THE DCIT, CIRCLE-2(1), THRISSUR vs. SRI.K.P. JOHNY, THRISSUR

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Dask.P. Johny Asst. Cit, Manappuram House Circle – 2(1) Hospital Road, Chalakkudy Aayakar Bhavan Vs. Thrissur 680307 Sakthan Thampuran Nagar [Pan:Acgpj4958G] Thrissur 680001 (Appellant) (Respondent) Asst. Cit, K.P. Johny Circle – 2(1) Manappuram House Aayakar Bhavan Hospital Road, Chalakkudy Vs. Sakthan Thampuran Nagar Thrissur 680307 Thrissur 680001 [Pan: Acgpj4958G] (Appellant) (Respondent)

143(3) of the Income Tax Act, 1961 (hereinafter "the Act") dated 14.12.2017 for Assessment Year (AY) 2014-15. 2. The background facts of the case are that the assessee, a dealer in old vehicles, was issued and served a notice u/s.148(1) of the Act on 20.03.2017, consequent to the survey under section 133A

SRI.K.P. JOHNY,THRISSUR vs. THE DCIT, CIRCLE-2(1), THRISSUR

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Dask.P. Johny Asst. Cit, Manappuram House Circle – 2(1) Hospital Road, Chalakkudy Aayakar Bhavan Vs. Thrissur 680307 Sakthan Thampuran Nagar [Pan:Acgpj4958G] Thrissur 680001 (Appellant) (Respondent) Asst. Cit, K.P. Johny Circle – 2(1) Manappuram House Aayakar Bhavan Hospital Road, Chalakkudy Vs. Sakthan Thampuran Nagar Thrissur 680307 Thrissur 680001 [Pan: Acgpj4958G] (Appellant) (Respondent)

143(3) of the Income Tax Act, 1961 (hereinafter "the Act") dated 14.12.2017 for Assessment Year (AY) 2014-15. 2. The background facts of the case are that the assessee, a dealer in old vehicles, was issued and served a notice u/s.148(1) of the Act on 20.03.2017, consequent to the survey under section 133A

INFOPARKS KERALA,COCHIN vs. THE ACIT, COCHIN

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

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

143(3) of the Income-tax Act, 1961 (‘the Act’ hereinafter) for the relevant years in first appeal by the Commissioner of Income-tax (Appeals)-2, Kochi [‘CIT(A)’ for short], vide his separate orders of even date (30.5.2014). The appeals raising the same issues; also decided likewise, were heard together, and are being disposed per a common order