Where revenue itself failed to enquire from assessee as regards the manner in which undisclosed income admitted under section 132(4) was derived, the assessee could not be held guilty of not substantiating the manner of deriving of such undisclosed income, therefore, no penalty under section 271AAA could be levied....

Where assessee having received share capital furnished evidences, i.e. addresses, PAN No., copies of returns and bank statements of subscribers, etc., AO was not justified in treating share application money as unexplained without rebutting such evidences....

Whether the reinvestment made by the assessee in 3 residential houses having common amenities, kitchen, common entrance, common house name, common electrical, common storage, common water, common garden, common boundary wall, common guard room, etc would give eligibility to claim exemption u/s 54 of the Act by construing all the three uni...

Hyundai Motor India appeal: Including bad debts and provision for bad and doubtful debts as operating expenses is necessary for the purpose of computing profit and loss of comparable companies, the margins of comparable companies ...

Where the income of the assessee was exempt under section 11 and the assessee was not carried on the business, section 40(a)(ia) had no application. Moreover, the insertion of Explanation 3 to Section 11 by the Finance Act, 2018 making inter alia the provisions of Section 40(a)(ia) applicable in case of charitable or religious trust or in...

The Registry has put a note that the applications are time barred by five days. However, Ld. Counsel for the assessee has submitted that in view of the settled legal position of law, the applications cannot be treated as time barred. He in this respect has invited our attention to the relevant provisions of section 254(2) of the Income-ta...

The learned Commissioner (A) ought to have appreciated that the return of income was filed electronically within the due date and filing of ITR-V was a formality and delay in filing ITR-V cannot deprive the assessee from claiming carry forward loss duly determined for the relevant assessment yeare....

A.O. noted that the deduction under section 80IC is to be allowed on the profits derived from eligible business. The interest earned on the FDRs cannot be said that interest income earned from manufacturing activities of the assessee. It can only be said that interest income on FDRs is attributable to business activities but cannot be sai...

In accordance with the view expressed by the third member, Hon'ble Vice-President, Hyderabad, the ground of appeal No.4 is partly allowed and the AO is directed to allow the deduction from the book profit of sum of Rs.22.89 crores while computing the taxable income u/s 115GB of the I.T. Act. The ground of appeal No.4 is therefore, treated...

Commission earned by non-resident for services rendered abroad could not be construed as incomes accrued or arisen in India and accordingly disallowance made by AO by invoking section 40(a)(i) was set aside....