DCIT Vs J. K. Techno soft Ltd (ITAT Delhi) Conclusion: Forward mark contracts on foreign currency was incurred during the normal course of business and the losses incurred were the part and parcel of the business activity of assessee, which were allowable as business expenditure and not speculative in nature, thus any expenditure incurred for […]
The statutory scheme underlying the Manufacture and Other Operations in Warehouse Regulations, 2019 (MOOWR) could not be construed as seeking to exclude solar power generation in terms of permissions granted under Section 65 of the Customs Act, 1962.
Issuance Of Letters Of Comfort/Support will Construe As International Transaction U/s 92B considering corporate guarantee issued by assessee could not be compared with the letters of comfort and therefore agreed with the computation of arm’s length rate of 0.04%.
Expenditure incurred by assessee should be disallowed to the extent that expenditure which had been incurred for evaluation of business opportunities that could not be said to be in line with the existing business or an extension of the existing business of assessee of manufacturing of paints and enamels.
Resolution Plan met the requirements of Section 30(2) of the Code and the Regulations 37, 38, 38(1A) and 39(4) of the CIRP Regulations. The Resolution Plan was not in contravention of any of the provisions of Section 29A of the Code and was in accordance with law.
Assessee was incorporated in Japan and was in the business of providing telecommunication services. Assessee provided fixed, mobile, wholesale, and associated telecommunication services across the globe.
Assessee had issued share application money and subsequently allotted shares which showed that the transactions were genuine and there was no material brought on record by tax authorities that the assessee had benefited from round-tripping, therefore, ITAT had deleted the addition made u/s 68.
Compensation by its very nature, had to be just. For suffering, no part of which was the claimant-appellant’s own fault, she had been awarded a sum which could, at best, be described as ‘paltry’. In regard to the application of the Eggshell-Skull Rule, the impugned judgment was silent as to how this rule applied to the present case.
Assessee had miserably failed to establish genuineness of the transaction by cogent and credible evidence and that the investments made in its share capital were genuine.
Supreme Court held that subject to statutory stipulation, a repealed provision ceased to operate from the date of repeal, and the substituted provision started operating as and when it is substituted.
