The facts of the case are that the assessee is a partnership firm and the Assessing Officer noticed that the debit balance in the partners’ account was more than the credit balance. He, therefore, charged the interest on the net debit balance of partners at the rate of 12% and accordingly made the addition of 20,61,845/-
In the present case it is apparent that on the date of search be on 12/09/2007, the assessments for assessment year 2004-05 & 2005-06 were already completed. There was no incriminating material found during search for these years as is apparent from arguments of Ld.
During the course of assessment proceedings, Assessing Officer noticed that Assessee has made investment in shares amounting to Rs. 95,45,400/-. Assessing Officer was of the view that the investment would generate exempt income and therefore provisions of section 14A becomes applicable.
The facts, in brief, are that a survey u/s 133A of the Act was carried out at the business premises of the assessee. As per the Revenue, an amount of Rs. 20 lacs was accepted as undisclosed income by the assessee on account of shortage of gold ornaments weighing 758.475 gms and excess stock of silver at 91.134 kms.
In our view, offering of the so called service to a particular section as in the instant case to members of the assessee organization only does not in any way lead to a charitable activity for the purpose of sec.2(15) of the Act.
Case of the assessee is covered by sub-clause (b) of clause 2 of Circular No. 7 dated 23-10-2007 and it is also covered by clause 2(b) of Circular No. 790 dated 20.04.2000. In para 2.1 of Circular 7 dated 23-10-2007, it is clearly provided that once the amount already remitted in pursuance
Amount of advance given to M/s Dhillon Kool Drinks and Beverages Limited was advanced in the course of business. It is undisputed that the advances became irrecoverable. In such situation, as per the ratio emanating from the decision of the Hon’ble Jurisdictional High Court in the case
In the case on hand, the issue of taxability of stock option is not in dispute as the assessee himself has offered the same to tax while filing his return of income. The only issue is the amount that can be brought to tax in India.
Since there is no monetary consideration involved in transferring the manufacturing division with all its assets and liabilities under scheme of amalgamation. it cannot be considered to be a slump sale within the meaning ascribed under section 2(42C)
Deemed dividend (to extent of accumulated profit) includes, Any payment by way of loan or advance by a closely-held company to a shareholder holding substantial interest. Such deemded dividend is treated as Income From Other Sources (IFOS) in the hand of such shareholder.
