The passport to derive benefit under sec. 54F(1) is investment in construction of property within the period required u/s 54(1)F or to invest in residential property within the stipulated time for enabling deduction under section 54F of the Act.
Since we have already held that the AO has conducted proper enquiry and has taken a plausible view, therefore, the order cannot be held to be erroneous, therefore, in absence of fulfillment of twin conditions, PCIT is not justified in invoking the jurisdiction u/s 263 of the IT Act, 1961.
In our considered opinion, additions which are mere estimated additions do not attract penalty u/s 271(1)(c) and it is not a fit case of levy of penalty.
ALP of corporate guarantee has to be determined as it falls within scope and ambit of an international transaction after retrospective amendment to section 92B and 0.5% corporate guarantee is held to be appropriate.
It is held that transaction within the family and close relative are covered by the proviso to section 56(2)(viii)(c) and there is no application of the said section for taxing the income under the head ‘Income from other sources’. The provisions of s. 56(2)(viii)(c)(ii) shall not apply in case of money or any property received from any close relative.
The assessee operates as a global services advisory and research company. Assessee assists corporations in developing and implementing leading edge sourcing strategies including captive outsourced and shared services approaches.
Vanditbhai Rajendrakumar Patel Vs ITO (ITAT Ahmedabad) Facts- The brief facts of the case were that as per AIR information, the Ld. Assessing Officer came know that the assessee had received cash deposits of Rs. 25,21,100/-in saving bank account maintained with Corporation Bank. To verify cash deposits, letter dated 10-02-2017 was served on the assessee, […]
Batra Enterprises Vs ACIT (ITAT Delhi) The facts relating to the ground are that during the course of assessment proceedings the Assessing Officer noticed that the assessee had made payment of Rs. 2,74,846/- being commission paid to Shri Ishan Batra. In response to the query of the Assessing Officer, the assessee had stated that Shri […]
DCIT Vs JLC Electromet Pvt. Ltd. (ITAT Jaipur) In the present case, undisputed facts are that the commission has been paid to various nonresident entities in respect of sales affected by the assessee outside of India, the services have been rendered outside of India and the payments have been made outside of India. In light […]
Smt. Manjulaben C. Tomar Vs ITO (ITAT Ahmedabad) The present application filed by the assessee seeks restoration of the appeal filed by the assessee in ITA No.956/Ahd/2012, pertaining to A.Y 2006-07 which was dismissed for want of prosecution vide order dated 27.03.2017. We have noted that the said appeal was disposed off without dealing with […]
