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

UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI

In the result, appeal filed by the assessee stands partly allowed\nfor statistical purpose and the stay application is dismissed as\ninfructuous

section 92CA(1) of the Act, to the Transfer Pricing\nOfficer (TPO) for the purpose of determination of ALP in respect of\nthe above international transaction.\n4\nThe TPO vide order dated 09/10/2023 passed u/s. 92CA(3),\nsuggested the TP adjustment in respect of software development\nagreement of Rs. 12,84,50,000/- and also interest on delayed\nreceivables

V D DEVASIA,KOTTAYAM vs. ACIT, KOTTAYAM

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

64 of the Act, justifying thus the inclusion of the sale of their land in his cash flow statement. Similarly, his land holding, after the sale in December, 2010, is at a mere 4.33 acres, which could not explain the huge agricultural income claimed by the assessee, viz. at Rs.102.94 lakhs for AY 2012-13, being in fact not disclosed

V D DEVASIA,KOTTAYAM vs. ACIT, KOTTAYAM

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

64 of the Act, justifying thus the inclusion of the sale of their land in his cash flow statement. Similarly, his land holding, after the sale in December, 2010, is at a mere 4.33 acres, which could not explain the huge agricultural income claimed by the assessee, viz. at Rs.102.94 lakhs for AY 2012-13, being in fact not disclosed

V D DEVASIA,KOTTAYAM vs. ACIT, KOTTAYAM

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

64 of the Act, justifying thus the inclusion of the sale of their land in his cash flow statement. Similarly, his land holding, after the sale in December, 2010, is at a mere 4.33 acres, which could not explain the huge agricultural income claimed by the assessee, viz. at Rs.102.94 lakhs for AY 2012-13, being in fact not disclosed

CHENGAZHASSERIL THOMAS KURIAN,KOTTAYAM vs. ACIT CENTRAL CIRCLE KOTTAYAM, KOTTAYAM

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

64 of the Act, justifying thus the inclusion of the sale of their land in his cash flow statement. Similarly, his land holding, after the sale in December, 2010, is at a mere 4.33 acres, which could not explain the huge agricultural income claimed by the assessee, viz. at Rs.102.94 lakhs for AY 2012-13, being in fact not disclosed

V D DEVASIA,KOTTAYAM vs. ACIT, KOTTAYAM

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

64 of the Act, justifying thus the inclusion of the sale of their land in his cash flow statement. Similarly, his land holding, after the sale in December, 2010, is at a mere 4.33 acres, which could not explain the huge agricultural income claimed by the assessee, viz. at Rs.102.94 lakhs for AY 2012-13, being in fact not disclosed

CHENGAZHASSERIL THOMAS KURIAN,KOTTAYAM vs. ACIT CENTRAL CIRCLE KOTTAYAM, KOTTAYAM

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

64 of the Act, justifying thus the inclusion of the sale of their land in his cash flow statement. Similarly, his land holding, after the sale in December, 2010, is at a mere 4.33 acres, which could not explain the huge agricultural income claimed by the assessee, viz. at Rs.102.94 lakhs for AY 2012-13, being in fact not disclosed

CHENGAZHASSERIL THOMAS KURIAN,KOTTAYAM vs. ACIT CENTRAL CIRCLE KOTTAYAM, KOTTAYAM

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

64 of the Act, justifying thus the inclusion of the sale of their land in his cash flow statement. Similarly, his land holding, after the sale in December, 2010, is at a mere 4.33 acres, which could not explain the huge agricultural income claimed by the assessee, viz. at Rs.102.94 lakhs for AY 2012-13, being in fact not disclosed

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

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

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