On the facts of this case, however, all that the Assessing Officer has indicated is that the assessee had a permanent establishment (PE) in India during the relevant period and that there was presumably some connection between the interest income of the assessee and the existence of the permanent establishment.
The undisputed fact is that nothing has happened during the year under consideration, the impugned land was converted into stock in trade in earlier assessment year. It is not in dispute that the agreement between the assessee and Unitech is not an agreement for sale and it is not in dispute that there is no consideration.
Shares are financial assets classified as tangible assets because they derive value from contractual claims. Hence, the same is not depreciable u/s 32 (1) (ii) of The Act.
Explore the detailed analysis of ITAT decision in Sports Club of Gujarat Ltd. vs. PCIT case regarding taxability of entrance membership fees and the principle of mutuality.
Explore the landmark ITAT Raipur case – Sheo Bhagwan Goel vs. ACIT, delving into arbitrary disallowance, self-made vouchers, and the crucial legal analysis leading to a favorable verdict.
Explore ITAT Delhi ruling in Sandeep Kumar Agarwal vs. ADIT, allowing employer deduction for EPF & ESIC, even if paid post EPF & ESIC due date but before income tax return deadline.
Held that mere extraordinary profit cannot be criteria for adjustment in the transfer price
Reopening reasons have to be read on standalone basis without any scope of addition, deletion or substitution therein even if supportive material emerges at a later stage.
Explore the dispute in Sh. Avtar Singh case where the Assessing Officer decision to reopen the assessment is challenged. Detailed analysis of cash deposits and legal aspects.
Rupal Jain Vs ACIT (ITAT Delhi) We notice that the assessee has not only discharged the primary onus by filing confirmation and the IT returns and balance sheet of the lenders, the assessee is also stated to have paid interest in most of the cases and deducted TDS thereon. Noticiably, the lenders are the family […]
