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

250 15 Reimbursement of expenses 1,07,78,001 16 Recovery of expenses 3,69,14,146 3. On noticing the above international transactions, the AO referred the matter to the Transfer Pricing Officer (TPO) u/s. 92CA(1) of the Act for the purpose of benchmarking the above international transactions. The TPO vide order dated 28.10.2016 3 Apollo Tyres

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

250 (including interest under section 234B of the Income- tax Act, 1961 (`the Act’) amounting to Rs.5,60,56,510); and (iii) Raising a net demand payable of Rs.20,55,69,980 upon the Appellant. Ground No.2 – Assessment and reference to Transfer Pricing Officer are bad in law. 2.1 The draft order issued by the Assistant Commissioner of Income

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

250 (including interest under section 234B of the Income- tax Act, 1961 (`the Act’) amounting to Rs.5,60,56,510); and (iii) Raising a net demand payable of Rs.20,55,69,980 upon the Appellant. Ground No.2 – Assessment and reference to Transfer Pricing Officer are bad in law. 2.1 The draft order issued by the Assistant Commissioner of Income

TORRY HARRIS SEA FOODS LTD,ALAPPUZHA vs. THE ACIT, ALAPPUZHA

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

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

transfer pricing provisions. You have claimed uniform adjustments @ 3% in all cases, without providing any clear rationale for the same. Adjustments have been claimed in an arbitrary manner without any factual and scientific basis being given. 'You have not submitted the quantification process adopted by you to arrive at the adjustments, claimed. The fact is that 3% adjustment was claimed

AVINISSERY SERVICE CO-OPERATIVE BANK LTD,THRISSUR vs. THE INCOME TAX OFFICER WARD 2(1),THRISSUR, THRISSUR

250 is expected to represent a conclusive adjudication on merits or at least the appellate authority's decision resolving the issues raised in the appeal. However, in the present case, the order in question being only a draft lacks finality and conclusiveness, thereby suffering from a fundamental procedural defect and is, therefore, void ab initio. Consequently, the impugned order deserves

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

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

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

THE DCIT, 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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

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

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient

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

250/- has been handed over to the college/trust in those only and the gross amount of collection solely belonged to the Trust/college. Hence, the assessment of donation in the hands of trustees was therefore not in order. 6.3 It was submitted that mere receipt of money would not constitute income in the hands of recipient