Plutus Industries Pvt. Ltd. Vs ITO (ITAT Delhi) We find the Assessing Officer in the instant case made addition of Rs.1,36,39,191/- u/s 68 of the Act in respect of unsecured loan obtained by the assessee from three directors on the ground that the assessee failed to substantiate with evidences to his satisfaction regarding creditworthiness of […]
Neelkamal Realtors Suburban Pvt. Ltd. Vs ACIT (ITAT Mumbai) ITAT find that identical issue has been decided by the co-ordinate Bench in case of Emdee Digitronics Pvt. Ltd Vs. PCIT in ITA No. 361/Kol/2019 dated 28th June, 2019, wherein the co-ordinate Bench in Para No.12 relying on the decision of M/s Naaraayani Sons Pvt. Limited, […]
DCIT Vs. Bhagyalaxmi Rolling Mill Pvt. Ltd. (ITAT Pune) The issue for adjudication in all these appeals is the assessee having received subsidy from Government of Maharashtra under Package Scheme of Incentives of 2007 (PSI-2007), Whether the said subsidy is capital receipt or a revenue receipt. The assessee-company had set up a mega project as […]
Balex Private Ltd. Vs ACIT (ITAT Ahmedabad) Ld. AR further submitted during the set-aside assessment proceeding the address to where notices alleged to have been served remained vacant and therefore, the assessee could not reply to the notices issued by the AO. The assessee came to know about the issuance of notice when the Authorised […]
Russell Reynolds Associates Inc. Vs DCIT (International Taxation) (ITAT Delhi) Facts- The Appellant, incorporated under the laws of the United States of America, filed its Income-tax return for relevant assessment showing income being royalty income received from Russell Reynolds Associates India Private Limited in terms of ‘Licensing Agreement’ for use of Intellectual Property Rights (‘IPRs’) […]
The entire case of the department is based on the un-corroborated entries found in the computer server which were retrieved by using the forensic tools. These alleged documents collected by the department from the computers of M/s.RNS Infrastructure Ltd., cannot be described as evidence so as to fasten the tax liability on the present assessee.
There is absolutely no dispute that the foreign reinsurers does not have any place of business in India / permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act.
Sandipkumar Parsottambhai Patel Vs ITO (ITAT Surat) We note that in assessees case, the assessing officer received information from the Investigation Wing, Kolkata who had carried out survey / search operations wherein it was established that in large number of penny stock companies share prices were artificially raised/manipulated on the Stock Exchanges in order to […]
Bharath Wind Farm Ltd Vs DCIT (ITAT Chennai) Upon careful consideration of factual matrix, it could be seen that the assessee has earned Carbon Credits in earlier years on the basis of wind-mill power generated during FYs 2007-08, 2008-09 & 2009-10. Recognizing the same in its books of accounts, the assessee booked income of Rs.305.59 […]
E-Land Systems Pvt. Ltd. Vs ITO (ITAT Bangalore) There is no dispute with regard to the fact that there could be a time gap between “setting up of business” and actual “commencement of business”. It is also settled principle that the expenses incurred after setting up of business is allowable as deduction. We may gainfully […]
