There is no reason or justification for the Court on the basis of the plain language used in sub-section (4) of section 234B to exclude the cases, where no interest has been levied on the assessee in the original order of assessment, from the liability to pay interest.
The assessee maintained regular books of account following recognized method of accounting. The assessee has shown 10.22% of G.P. for the year under consideration as against 6.78% GP of last year. Search and seizure actions were carried out on 14.6.2006.
This appeal, by special leave, at the instance of the Revenueis directed against the judgment and order dated 27th June, 2001 delivered by the High Court of Gujarat at Ahmedabad in Income Tax Reference No. 44 of 1986. By the impugned judgment, the High Court has answered the following questions
Where the assessee company executed a works contract of design, development, commissioning etc., of an oil free compressor system for its client during the period 1997–2001 it was held that the assessee is not liable under ‘consulting engineering services’ – (i) since services rendered by ‘companies’ were not liable prior to 1.5.2006 under this category; (ii) since the assessee company’s service fall under works contract services which was brought into the ambit of service tax only w.e.f. 1.6.2007.
It has been held by various judicial pronouncements that unless proper method is followed, comparables are chosen and selected after doing a proper FAR study as well as adjustments are made to the extent possible it would be unfair to summarily reject the transfer pricing analysis made by the assessee
Once the rectification application filed by one of the parties is considered and decided by the Tribunal rightly or wrongly, another rectification application on same issue is not maintainable against the order issued by the Tribunal under section 254(2)
The AO further made a disallowance of a deduction of Rs.6,94,02,867/- u/s 40(a). The assessee claimed that certain disallowances were made for expenditure in the earlier years in the case of KEC Infrastructure Ltd. and as the payments of these disallowed expenditure were made during the year, the assessee claims that the same should be allowed in its han
Whether on the facts and in the circumstances of the case and in law, the Tribunal was erred in holding that while computing direct cost attributable to export the freight and insurance amounting to Rs.1,71,87,614/should be excluded for arriving at export profits while computing the deductions u/s. 80HHC.
A search was conducted on 18.01.2001 and it was said to have been completed in March 2001. The notice under Section 158BC of the said Act was served on the assessee on 03.12.2001 and the assessee filed the return on 31.12.2002. According to the learned counsel for the assessee / appellant, the notice under Section 143(2) of the said Act read with the provisions of Section 158BC(b) could have been issued by 31.12.2003, i.e., within the period of twelve months fro
The issues involved in this appeal are that ld. CIT(A) confirmed the additions in respect of gifts claimed to have been received by the assessee for Rs. 1,00,000/- each from Smt. Sushilaben and Smt. Manjulaben. During the assessment year in question the assessee has shown to have received following gifts.
