In this case assessee, was doing embroidery work on job work basis. The embroidery activity, according to the Tribunal, also results in production of a new article having a different market of its own and there are various stages involved in embroidery activity, as follows: i) Creating a digitalized embroidery design file
Smt. Sumitra Devi Agarwal Vs. ITO (ITAT Jaipur)- The AO has questioned the genuineness of the liability and in absence of the requisite confirmation, has held the same to be a bogus liability. Where the liability itself has been held to be a bogus liability, where is the question of remission or cessation thereof.
In this case During scrutiny assessment proceedings, the Assessing Officer inter alia disallowed writing off of bad debts of M/s. Kinetic Motor Co. Ltd. amounting to Rs.1,27,58,427/- as the same was Group Concern and AO further claimed that The debts have been written off as bad debts only to suppress the income.
Bhujbal Brothers Construction Company V/s. DCIT (ITAT Pune) Deduction u/s. 80I1B(10) on housing project at Damodar Residency has been denied primarily on two counts(i) the area of the housing project is less than 1 acre, and (ii) the land on which the housing project has been developed does not belong to the assessee.
M. Natarjan Vs. DCIT (ITAT, Chennai) Addition on behalf of undisclosed income of various amounts has been made against the assessee. Before ITAT assessee raised additional ground that addition was made before approval of concerned authorities prescribed u/s 158BG and hence invalid.
ACIT vs. Rahul Pancholi (ITAT Jaipur) AO find decline in gross profit rate in current year in comparison to previous year. On examination of books of account AO found discrepancies in accounts. He made additions after rejecting books of account u/s 145 (3).
In the case of Bhavya Anant Udeshi Vs ITO (International Taxation) it was held by ITAT Hyderabad that provision of section 50C being a deeming provision, it cannot be used for the purpose of imposition of penalty under section 271(1)(c) unless it is proved that Assessee has received any amount over
ITAT Ahmedabad has held in the case ITO v Someshwar Real Estate Pvt. Ltd. that the TDS would be deducted u/s 194C only when the amount of single contract exceeds Rs. 20,000 or the amount exceeds Rs. 50,000 in aggregate which has been given to a particular person in a year.
ITAT Chandigarh held In the case of DCIT vs. M/s Indo Soviet Friendship that the Assessing Officer has not brought any material on record as to how he has given his finding that the cars have been purchased for the benefit of the Chairman.
ITAT Delhi has held in the case of ITO, TDS vs. Nokia India Pvt. Ltd that services rendered does not qualify as FTS for technical services under the India Finland Tax Treaty if service provider has not made available to assessee any technical knowledge skill
