The court considered the reasoning of the Revenue and held, firstly as the arrangement was in place with the UTI (which had to purchase the NCDs at Rs. 389/- per NCD), the assessee gave effect to it (the arrangement). UTI paid Rs. 389/- per debenture to JISCO
The substantial time as extended in the previous judgment of this Court in Commissioner of Income Tax (TDS)-I vs. C.J.International Hotels Pvt. Ltd. (in ITA No.57/2015) decided on 09.02.2015, as discussed elaborately in a reasoned order of this Court
Whether CIT can give approval for initiating proceeding u/s 147 in place of JCIT who is prescribed authority to give such approval u/s 151 (2) of the Income-tax Act.
Whether a proportion of the project receipts, commensurate with the risks/performance obligations, should be attributed to the assessee JV to whom tender had been awarded for the project and undertook significant risks and responsibilities for the completion of the project
Hon’ble court has observed that in the case of Bajrang Lal (supra) it was held that it is settled law that the primary burden to prove understatement or concealment of income is on the Revenue and it is only when such burden is discharged it would be permissible to rely upon the valuation given by the DVO.
Whether revenue is right in passing order giving instruction to bank to pay 50% of the demand raised against assessee when appeal against the assessment order was pending before CIT (A).
The appellant is urging this Court to dwell deep into the factual material and render findings of fact of which the jurisdiction of this Court does not permit such an inquiry as the high court cannot entertain an appeal which involves only factual issue.
In the case of M/s.A.B.Agencies Vs. Customs, Excise and Service Tax Appellate Tribunal, it was held by Kerala High Court that a CHA cannot be absolved of his lapse of supervision and misconduct of his employees attracting Clause 19 of the Regulations warranting action against him under Regulation 20.
Punjab & Haryana High Court in the case of Bellsonica Auto Components India Private Limited held that services directly or indirectly used in relation to manufacture of final products are eligible for Cenvat credit.
In the cited case, Delhi High Court held that the building had been developed to be sold or let out with no possibility of the terrace floor being subjected to such utilization. As there is no other purpose to be served by the property held on the terrace floor
