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

201 (1) of the Act. However the same cannot be considered as the 2nd proviso to section 40(a)(ia) is applicable w.e. f. 1-4-2013, i.e. from A Y IT(TP)A Nos.475 & 134/Coch/2016. 14 M/s.US Technology Resources Pvt.Ltd. 2013-14.This is also clarified in the explanatory memorandum to Finance bill, 2012. 5.7 The A.O. further observed that since

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

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

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

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 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

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

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

201 on the ground that the\nThe Deputy\nCommissioner of\nIncome Tax,\nCorporate Circle\n1(1),\nCochin\nVs.\nRESPONDENT\nPage 3 of 8\nITA Nos. 720 to 724/Coch/2023\nassessee had not deducted tax at source u/s. 195 of the Act as against the\npayments made to the said two entities on the ground that the said non\nresidents have business

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

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

201 on the ground that the\nassessee had not deducted tax at source u/s. 195 of the Act as against the\npayments made to the said two entities on the ground that the said non\nresidents have business connection in India. The assessee's appeal was also\ndismissed by the Ld.CIT(A). Thereafter the assessee filed an appeal before\nthe

ACEELERATED FREEZE DRYING CO.LTD,ALAPPUZHA vs. DCIT, ALAPPUZHA

In the result, the appeal of the Revenue is allowed and the appeal of the

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

201 & 281/2010 wherein the High Court vide judgment dated 02-08-2018 remitted the issue to the file of the Tribunal with the following observation: “Especially noticing the long pendency, we request the Tribunal to dispose of the appeals within a period of six months from the date of receipt of a certified copy of this judgment.” Hence, these appeals

DCIT, ALAPPUZHA vs. M/S ACEELERATED FREEZE DRYING CO, LTD, ALAPPUZHA

In the result, the appeal of the Revenue is allowed and the appeal of the

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

201 & 281/2010 wherein the High Court vide judgment dated 02-08-2018 remitted the issue to the file of the Tribunal with the following observation: “Especially noticing the long pendency, we request the Tribunal to dispose of the appeals within a period of six months from the date of receipt of a certified copy of this judgment.” Hence, these appeals

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

In the result, the appeals of the assessesin ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

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

In the result, the appeals of the assesses in ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

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

In the result, the appeals of the assessesin ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

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

In the result, the appeals of the assessesin ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT, KOTTAYAM

In the result, the appeals of the assesses in ITA no

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

1),theargument before the Supreme Court was arising out of the return of income of the assessee. The amountreceived by the asessee on surrender of tenancy right, whether liable to capital gains under section 45 of the Income Tax Act, 1961 was involved in that appeal before the Supreme Court. There was a lease agreement entered into in the year