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68 results for “transfer pricing”+ Section 36(1)(vii)clear

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Key Topics

Section 250120Section 220(2)12Section 15412Section 244A12Section 234D6Section 244a6Section 1536Rectification u/s 1546Section 143(3)4

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

Appeal is allowed

ITA 288/COCH/2024[2019-2020]Status: DisposedITAT Cochin23 Oct 2024AY 2019-2020

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Naresh S., CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 153Section 154Section 220(2)Section 234DSection 244ASection 244aSection 250

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

Showing 1–20 of 68 · Page 1 of 4

Addition to Income4
Unexplained Investment2
Cash Deposit2

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

Appeal is allowed

ITA 285/COCH/2024[2013-2014]Status: DisposedITAT Cochin23 Oct 2024AY 2013-2014

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Naresh S., CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 153Section 154Section 220(2)Section 234DSection 244ASection 244aSection 250

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

ITA 286/COCH/2024[2014-2015]Status: DisposedITAT Cochin23 Oct 2024AY 2014-2015

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Naresh S., CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 153Section 154Section 220(2)Section 234DSection 244ASection 244aSection 250

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, RANGE-1, THRISSUR

Appeal is allowed

ITA 283/COCH/2024[2008-2009]Status: DisposedITAT Cochin23 Oct 2024AY 2008-2009

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Naresh S., CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 153Section 154Section 220(2)Section 234DSection 244ASection 244aSection 250

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

ITA 233/COCH/2024[2006-2007]Status: DisposedITAT Cochin23 Oct 2024AY 2006-2007

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Naresh S., CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 153Section 154Section 220(2)Section 234DSection 244ASection 244aSection 250

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

ITA 232/COCH/2024[2004-2005]Status: DisposedITAT Cochin23 Oct 2024AY 2004-2005

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Naresh S., CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 153Section 154Section 220(2)Section 234DSection 244ASection 244aSection 250

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.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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

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

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

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 Ltd. passed u/s. 92CA(3) of the Act suggested upward TP adjustments in respect of corporate guarantee commission provided to Apollo Vredestein BV (AVBV

FEDBANK FINANCIAL SERVICES LIMITED,ERNAKULAM vs. THE DCIT CIRCLE 1(1), KOCHI, KOCHI

In the result, the appeal of the assessee is allowed

ITA 838/COCH/2022[2017-2018]Status: DisposedITAT Cochin08 Mar 2023AY 2017-2018

Bench: Shri George George K. & Ms. Padmavathy S.Assessment Year : 2017-18

For Appellant: Ms. K. Parvathy Ammal, CAFor Respondent: Shri Prashanth V.K., CIT(DR)
Section 143(3)Section 263Section 36Section 36(1)(viia)Section 37

vii) provides that “the amount of any bad debt or part thereof which is written off as irrecoverable in the books of accounts of the assesse for that previous year is an allowable deduction”. The said section is subject to provisions of sub section (2). Section 36(2) provides that “no deduction shall be allowed unless such debt or part

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

ITA 254/COCH/2019[2014-15]Status: DisposedITAT Cochin09 Oct 2023AY 2014-15

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)

For Appellant: Shri T.M. Sreedharan, Sr. Advocate (with Smt. Divya Ravindran, Adv. with him)For Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 131(1)Section 133ASection 147Section 148(1)Section 69

price - the date of transfer (b) Non-reference to the internal audit report or its findings, vital for share valuation; (c) Complete silence and non-explanation as to how and why payment of sale consideration, being, in clear terms of SA to the party of the first part, the seller, stands made to Manko, the company for purchase of shares

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

ITA 206/COCH/2019[2014-15]Status: DisposedITAT Cochin09 Oct 2023AY 2014-15

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)

For Appellant: Shri T.M. Sreedharan, Sr. Advocate (with Smt. Divya Ravindran, Adv. with him)For Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 131(1)Section 133ASection 147Section 148(1)Section 69

price - the date of transfer (b) Non-reference to the internal audit report or its findings, vital for share valuation; (c) Complete silence and non-explanation as to how and why payment of sale consideration, being, in clear terms of SA to the party of the first part, the seller, stands made to Manko, the company for purchase of shares

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

In the result, appeal of the assessee is hereby dismissed

ITA 506/COCH/2024[2019-20]Status: DisposedITAT Cochin20 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 436/COCH/2024[2014-2015]Status: DisposedITAT Cochin20 Dec 2024AY 2014-2015

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 454/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 455/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

A B C SALES CORPORATION ,KANNUR vs. ITO, CIRCLE-1, KANNUR

In the result, appeal of the assessee is hereby dismissed

ITA 404/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 505/COCH/2024[2018-19]Status: DisposedITAT Cochin20 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 439/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 498/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 504/COCH/2024[2020-21]Status: DisposedITAT Cochin20 Dec 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

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

In the result, appeal of the assessee is hereby dismissed

ITA 438/COCH/2024[2016-2017]Status: DisposedITAT Cochin20 Dec 2024AY 2016-2017

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming