Sanmina-SCI Technology India Private Ltd. Vs ACIT (Madras High Court) Explanation 2(c) to Section 147 will not come to the aide of the relevance as, while the income chargeable has been made subject to excessive relief, the explanation cannot override the statutory prescription of limitation as set out in the proviso to Section 147. The purpose of the […]
Harish Sharma Vs ITO (ITAT Chandigarh) Admittedly, in the present case the notebook entries containing entry pertaining to the business of M/s Sharma Overseas Services was recovered from the possession of the assessee. The authorities below have not rejected the contention of the assessee that the entries in note book pertained to the business concern […]
ACIT Vs Hirapanna Jewellers (ITAT Visakhapatnam) In the instant case the assessee has established the sales with the bills and representing outgo of stocks. The sales were duly accounted for in the books of accounts and there were no abnormal profits. In spite of conducting the survey the AO did not find any defects in […]
DCIT Vs Saroj Kumar Poddar (ITAT Kolkata) Kolkata bench first of its kind of Interim order on the subject of endless adjournments by revenue on pretext of covid 19 and resultant pains to tax payer languishing for justice held remarkably as follows:- The Revenue is also raising strong objections, without any valid ground, for the […]
DCIT Vs Kewalram Textile Pvt. Ltd. (ITAT Ahmedabad) The power of the appellate authority to direct for the production of a document or examination of the witness as a matter of fact is in furtherance of any enquiry contemplated by Section 250(4) of the Act is contained in sub Rule 4 of Rule 46-A of […]
SAS Fininvest LLP Vs National-Assessment Centre Income Tax Department New Delhi (Delhi High Court) DELHI HIGH COURT admitted writ petition on account of not giving proper show cause notice (SCN) with material prior to passing of assessment order against NFAC. Also first time honourable court took cognizance of board instructions cited by us and reproduced […]
High Court After Taking Cognizance of Delayed Disposal of Appeals under Faceless Appeal Scheme, 2020 Directed Commissioner of Income Tax (Appeals) On Account of Principles of Natural Justice To Decide Appeal Expeditiously Within 12 Weeks.
ITAT Chandigarh addresses limitations, record definition, and right to be heard in Amrik Singh Bhullar Vs ITO case. Important insights for taxpayers.
The main issue in this appeal is whether loss from sale of long term capital share on which security transaction tax has been paid should be allowed to be carried forward for set off even though the income from such transfer of long term capital asset is exempt u/ s 10 (38).
It is undisputed fact that the consideration is paid to individuals who had experience in the business of consultancy for not to engage themselves in similar kind of business and activities for a period of 3 years. It is also not disputed that such consideration is independent and not part of the cost of acquisition of business paid to shareholders.
