M/s. Prayag Polytech Pvt. Ltd Vs ACIT (ITAT Delhi) We find that evidences which have been furnished by the assessee have not been discussed; and if the Director has not been found then it cannot be said that identity of the company is not established especially in wake of income tax records and share allotment […]
Aristo Industries Vs ITO (ITAT Kolkata) It is not in dispute that the assessee had maintained separate books of accounts for trading activity and manufacturing activity. We find that the assessee had claimed deduction u/s 80IE of the Act only in respect of profits derived from manufacturing activity only. It is not in dispute that […]
Macquarie Global Services Vs DCIT (ITAT Delhi) Once the claim of deduction u/s 10AA has been accepted in the first year of the operations and also in the second year, then in the third year same cannot be withdrawn by examining the factors which were required to be seen in the first year of the […]
This is an appeal filed by the assessee against the order of Commissioner (Appeals)- 46, Mumbai dated 20-1-2017 for assessment year 2011-12 in the matter of order passed under section 143(3) of the Income Tax Act wherein following grounds have been taken by the assessee
Provisions of section 2(22)(e) related to deemed dividend are not applicable where the relevant transactions are in the nature of current account transactions and not loans and advances.
United Education Society Vs JCIT (ITAT Delhi) Undisputedly, the assessee society is registered under section 12A of the Act as a charitable trust engaged in charitable activities for imparting education through its colleges. It is also not in dispute that the assessee society has been claiming exemption under section 11 of the Act on the […]
Membership fee and contribution from members received by IZA Belgium from the Indian members would not be liable to Income-tax in India under the provisions of the Income-tax Act, 1961 or the India-Belgium DTAA.
Lloyd’s Register Quality Assurance Ltd. Vs DCIT (ITAT Mumbai) Undisputed facts are, the Assessing Officer by treating the management charges as Head Office expenses has restricted the claim of the assessee to 5% of the total adjusted income in terms of section 44C of the Act. Whereas, learned Commissioner (Appeals) relying upon the order passed […]
ACIT Vs M/s. Splendor Landbase Limited (ITAT Delhi) It is seen that section 153A starts with Non obstante clause which inter alia overrides the provisions of section 139. This shows that return filed under section 153A is a separate return. Ld. AR relied upon the judgment of Jurisdictional High Court of Delhi in the case […]
M/s. Hinduja Group India Ltd Vs ACIT (ITAT Mumbai) Submission of detailed submitted before AO in summarised & Tabular Form before CIT cannot be considered as submission of any new evidence Power of the appellate authority clearly overrides the provisions of sub-rules (1), (2) and (3) of rule 46A and it is open to the […]
