Delhi ITAT has allowed the proportionate allocation of deemed dividend on the basis of the shareholding of the borrowing company. We find this Judgment to be wholly inapplicable to the facts of the present case as in the facts of this decision, both the shareholders were holding more than 10% in the lending company and more than 46% in borrowing company.
Pr. CIT Vs M/s TIBCO Software (India) Pvt Ltd (Bombay High Court) Any inclusion or exclusion of comparables per se cannot be treated as a question of law unless it is demonstrated to the Court that the Tribunal or any other lower authority took into account irrelevant consideration or excluded relevant factors in the ALP […]
Rastriya Saksharta Mission Innovative Technologies Education, Khesra Vs. CIT (ITAT Delhi) Section 12AA of the I.T. Act provides that ‘Pr.CIT or CIT on receipt of an application for registration of a trust or institution under section 12A, shall after satisfying himself about the objects of the trust or institution and the genuineness of its activities, […]
When a notice under section 263 dealt with several issues, which were not subject-matter of re-assessment proceedings, then, two years period contemplated under section 263(2) would begin to run from date of original assessment and not from date of re-assessment, CIT issued notice under section 263 from date of re-assessment, therefore, the same lacked jurisdiction as it was hit by limitation, thus, the notice was quashed.
Key Points – Companies (Amendment) Ordinance, 2018 With Corresponding Sections of Companies Act, 2013 On President’s assent to promulgation, Companies Act, 2013 has been amended through Companies (Amendment) Ordinance, 2018 passed by Ministry of Law and Justice on 2nd November, 2018. Major amendments along with their Corresponding sections of the Companies Act, 2013 are being […]
Notified from: 26th December 2016 Applicability: Applicable to both public & private companies. However, Section 248(2) is not applicable to section 8 companies. Strike off grounds: Sec 248 of Companies Act, 2013 deals with the provisions of strike off the name of company from register of companies. This section provides for two grounds for strike […]
The loss due to foreign exchange fluctuation in foreign currency transactions in derivatives has to be considered on the last date of account year and it is deductible under section 37(1) and could not be considered as a notional loss.
It is alleged by the petitioner that though he has attempted to upload FORM GST TRAN-1 within the time, he was not able to do so on account of some system error. The petitioner, therefore, seeks appropriate directions so as to enable him to take credit of the input tax available to him at the time of migration.
M/s. Haryana Distillery Limited Vs JCIT (ITAT Delhi) Section 272A(2)(k) of the I.T. Act provides penalty for failure to deliver or cause to deliver a copy of the statement within the time specified in sub-section (3) of Section 200 or the proviso to sub-section 3 of Section 206(c) of the I.T. Act. Section 273B of […]
Here are the things, which, if followed, I assure that you will be confident in each of your exam (provided you have completed the subject 2-3 times): 1. Sleep for 7 hours in the night just before the day of your exam. That is only way to RECALL everything you have read so far while writing the exam
