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

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

transfer pricing adjustment of Rs. 3.07.02.519% on Cost-to-Cost Recovery of Salary expenses from AEs a. On the facts and in the circumstances of the case and in law, the Ld. AO/TPO/DRP grossly erred in not appreciating that the recovery of salary expenses of Rs. 14,38,73,097/- (which was rectified by Ld. TPO vide its Order

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

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

35, 4th Floor,\nGCDA Commercial\nComplex,\nMarine Drive,\nCochin,\nKerala - 682 031.\nPAN: AAACC9658B\nAPPELLANT\nAssessee by\n:\nShri Gopi K, СА\nRevenue by\n:\nShri Omanakuttan, Snr. AR\nDate of Hearing\n:\n02-07-2025\nDate of Pronouncement\n:\n23-09-2025\nORDER\nPER SOUNDARARAJAN K., JUDICIAL MEMBER\nThese are the appeals filed by the assessee challenging the separate

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

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

35, 4th Floor,\nGCDA Commercial\nComplex,\nMarine Drive,\nCochin,\nKerala - 682 031.\nPAN: AAACC9658B\nAPPELLANT\nThe Deputy\nCommissioner of\nIncome Tax,\nCorporate Circle\n1(1),\nCochin\nVs.\nRESPONDENT\nAssessee by : Shri Gopi K, CA\nRevenue by : Shri Omanakuttan, Snr. AR\nDate of Hearing : 02-07-2025\nDate of Pronouncement : 23-09-2025\nORDER\nPER SOUNDARARAJAN K., JUDICIAL MEMBER\nThese

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

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

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

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

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

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

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

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

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

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

ABC SALES CORPORATION,KASARAGOD vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT, CENTRAL CIRLCE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

ABC BUILDWARES(P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1`, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT CENTRAL CIRCLE-1, CALICUT

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

ABC SALES CORPORATION,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

ABC BUILDWAERS INDIA (P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

BATHX BATHWARE INDIA PRIVATE LIMITED,KOCHIN vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that

K.ABDUL VAHEED,TALIPARAMBA vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

35,110/- ABC Sales Rs. 6,34,89,041/- Rs. 4,63,48,467/- Rs. 1,71,40,574/- Taliparamba Rs. 9,22,75,684/- Total Difference . ITA No.404 & others/Coch/2024 Page 53 of 165 50.1 In view of the above differences between the actual stock and the stock recorded in the books of account, the Assessing Officer (AO) concluded that