Assessee submitted the documentary evidence to show that after purchasing the property there was a civil suit filed by the other parties and the assessee could not complete the construction and the licence for constructing the house was accordingly delayed.
The reasons supplied to the assessee for reopening of the case relates mainly to Share capital, which is already been investigated by Assessing officer in detail during Original Assessment. Therefore, The present exercise of issuing the notice under Section 148 of the Act would amount to nothing but a change of opinion, which is not permissible.
One of the necessary conditions for holding that an agent constitutes a PE of an enterprise is that the agent must have an authority to conclude contracts or should have been found to be habitually entering into or concluding contracts on behalf of the enterprise.
This appeal filed by the Revenue raises questions with regard to whether transfer pricing adjustment consequent to arriving at Arms Length Price(ALP) is required to be done only in respect of the international transactions or this adjustment is to be done in respect of all the business transactions of the assessee i.e. at the entity level.
Delhi HC helkd that, All India Congress Committee (AICC) and Indian National Congres (INC) Delhi are not eligible to claim exemption u/s 13A of Income Tax Act for AY 1994-95 & 1995-96. The Court further holds that voluntary contributions received by political parties cannot be equated with corpus donation or capital receipts.
Section 40 (a) (i), in providing for disallowance of a payment made to a non-resident if TDS is not deducted, is no doubt meant to be a deterrent in order to compel the resident payer to deduct TDS while making the payment.
The Hon’ble Madras High court in the above cited case held that central govt can notify a country as notified jurisdictional area u/s 94A inspite of the fact that there exist a Double Tax Avoidance Agreement provided the DTAA is not serving the intended purpose for which it was entered into.
Invoking extraordinary jurisdiction of this Court under Article 226 of the Constitution of India, the petitioner herein has filed the instant writ petition seeking quashment of charge-sheet filed against him by jurisdictional police in the criminal court alleging the commission of offence under Section 21 (2) of the Protection of Children from Sexual Offences Act, 2012 (hereinafter called as “P0SCO Act”).
It is held that deduction u/s 80P is allowable to a primary agricultural credit society. In the instant case , assessee being a registered society classified in bye-laws as primary agricultural credit society is entitled to claim exemption u/s 80P.
HC held that while disposing off an application for registration u/s 12AA , the CIT is required only to verify the geniuses of the trust’s activity so as to ensure that the same matches with the objects stated in the trust deed.
