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

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

section 9(1)(vii) of the Act. If the said\npayment would fall u/s. 9(1)(vii), whether the said payments are eligible for\nexemption as per the DTAA. Finally, the AO arrived the conclusion that the\nnon-residents do not have any business connection and PE in India. The\nAO further held that the fees payable to the said

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

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

section 9(1)(vii) of the Act. If the said\npayment would fall u/s. 9(1)(vii), whether the said payments are eligible for\nexemption as per the DTAA. Finally, the AO arrived the conclusion that the\nnon-residents do not have any business connection and PE in India. The\nAO further held that the fees payable to the said

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 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

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. JCIT, RANGE-1, THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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. DCIT, THRISSUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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

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

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

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

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

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

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

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

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

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

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

In the result, the appeal of the assessee is allowed

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

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

US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, appeal filed by the assessee is partly allowed of statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)

section 234B and 234C of the Act The Appellant craves leave to add to or alter, by deletion, substitution, modification or otherwise, the above grounds of appeal, either before or during the hearing of the appeal.” 3. At the outset, we note that the learned AR for the assessee before us submitted that issue raised by the assessee in ground

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

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)

1 cr. has been received by the shareholders; the balance being to Manko for paying off its liabilities, proved by it’s books, extracted in the relevant part in the impugned order. As such, even as SA specifies the sale consideration at Rs. 675 lacs, it delineates its payment, being Rs. 575 lacs to the company itself, which credits

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

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)

1 cr. has been received by the shareholders; the balance being to Manko for paying off its liabilities, proved by it’s books, extracted in the relevant part in the impugned order. As such, even as SA specifies the sale consideration at Rs. 675 lacs, it delineates its payment, being Rs. 575 lacs to the company itself, which credits

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

9,22,75,684/- was made arbitrarily without due inquiry and consideration of the explanation provided by the assessee. Therefore, we are inclined to allow the appeal of the assessee on this ground and direct the deletion of the addition. 55.1 Therefore, considering the fact that the addition on account of the variance in stock was made solely based

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

9,22,75,684/- was made arbitrarily without due inquiry and consideration of the explanation provided by the assessee. Therefore, we are inclined to allow the appeal of the assessee on this ground and direct the deletion of the addition. 55.1 Therefore, considering the fact that the addition on account of the variance in stock was made solely based

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

9,22,75,684/- was made arbitrarily without due inquiry and consideration of the explanation provided by the assessee. Therefore, we are inclined to allow the appeal of the assessee on this ground and direct the deletion of the addition. 55.1 Therefore, considering the fact that the addition on account of the variance in stock was made solely based