We also note that the Delhi High Court in Commissioner of Income Tax Vs. Keihin Panalfa Ltd. (ITA No.11 of 2015) decided on 9th September, 2015 has while dealing with transfer pricing adjustment in the absence of segmental accounts held that adjustments have to be restricted only to transactions with Associated Enterprises. It further held that whereseparate accounts are not available, then proportionate adjustments to be made only in respect of the international transactions with Associated Enterprises.
This petition challenges notice dated 31st March, 2016 issued under Section 148 of the Income Tax Act, 1961. The impugned notice seeks to reopen the assessment for Assessment Year 2009-10. The regular assessment proceedings were completed on 28th December, 2011 under Section 143(3) of the Act.
Rule. Mrs. Mauna N. Bhatt, learned advocate waives service of notice of rule on behalf of the respondents. In the facts and circumstances of the case and with the consent of the learned advocates appearing for the respective parties, the present petition is taken up for final hearing today.
The petitioner has challenged a notice dated 29.3.20 14 by which the respondent no.1 Assessing Officer sought to reopen the assessment of the petitioner for the assessment year 2009-2010.
Aassessment order itself reveals that the Revenue has placed reliance on the proceedings initiated against the appellant for imposition of penalty under Section 67 of the KVAT Act based on an inspection held on 17.08.2006. It is seen that the Revenue relied on letter dated 18.09.2007 issued by V. Ahammed to the Assistant Director of […]
The fact that certain assets of undertaking are left out of sale transaction because it would cause inconvenience for purchaser does not mean that transaction is not a slump sale
Every child has a right to love and be loved and to grow up in an atmosphere of love and affection and of moral and material security and this is possible only if the child is brought up in a family. The most congenial environment would, of course, be that of the family of his biological parents.
This Appeal under Section 260-A of the Income Tax Act, 1961 (the Bombay Act) challengesthe order dated 6th December, 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order is in respect of Assessment Year 2006-07.
Where no possession had been given by the transferor to the transferee of the entire land in part performance of JDA so as to fall within the domain of section 53A and in absence of registration of JDA, although executed afterwards, the agreement did not fall under section 53A and consequently section 2(47)(v) did not apply and no further amount had been received and no action thereon had been taken, therefore, appeal of Revenue was dismissed.
A plain reading of Section 10(15)(iv)(c) clearly bears the fact that its approval of the Central Government which is necessary – not with respect to the transaction per se but with regard to the rate of interest.
