ACIT Vs Groz Engineering Tools Pvt. Ltd. (ITAT Delhi) Non-residents have rendered the services outside India and have been paid in foreign currency. Therefore, no income accrues or arises in India. These nonresidents do not have any PE or business connection in India which is not doubted by the AO. Further, the Assessing Officer has […]
Receipts from sale of scrap being part and parcel of the activities and being approximate thereto would also be within the ambit of gains derived from industrial undertaking for the purposes of computing deduction u/s 80IB
Sak Industries Pvt. Ltd. Vs DCIT (ITAT Chennai) We find that the assessee has purchased 1,25,000/- equity shares of ING Vysya Bank during the month of January and February, 2009 and subsequently during the month of September, 2009 all the shares are sold. The assessee also shows the above transaction in its books of accounts […]
ACIT Vs Ramona Pinto (ITAT Mumbai) As regards the merits of the case, we find that the assessee has received an arbitration award for Rs.28 crores, upon relinquishment of her rights in the partnership of M/s. P. N. Writer & Co. Here it may be gainful to recount the brief history of the case which […]
Rameshwar Prasad Shringi Vs PCIT (ITAT Jaipur) Assessing officer has carried out exhaustive enquiries and verifications regarding source of cash deposits in the bank account during the financial year relevant to impugned assessment year. The bank statements, the cash book, the ledger accounts, the financial statements for the year under consideration and for the earlier […]
Education cess was an allowable deduction while computing the income under the head profits and gains from business or profession as it did not fall within section 40(a)(ii).
Wieland Metals India Private Ltd. Vs ITO (ITAT bangalore) Issue before us is with regard to TP adjustment by applying TNMM by the TPO instead of CUP method adopted by the assessee as most appropriate method in respect of determining of ALP of manufacturing segment. As seen from the details of international transactions, the assessee […]
Universal Buildrise Private Limited Vs ITO (ITAT Delhi) M/S. Universal Buildrise Private Limited (Appellant) filed an appeal against Order dated September 30, 2019 of the Ld. CIT(A)-9, New Delhi, relating to the Assessment Year (AY) 2016-2017. The Appellant filed its return of income declaring loss and paid taxes on book profit under Minimum Alternate Tax […]
Jodhpur Bench held that mere time gap between withdrawals and deposits cannot be a sole basis for rejecting the explanation of the Appellant as there was no material that amount so withdrawn had been utilized somewhere else. The Court believed that the explanation by the Appellant was reasonable and therefore, directed that the addition so made must be deleted.
On the basis of incriminating material found, once reassessment proceedings was initiated on the basis of incriminating material found in the search of 3rd party then the provisions of section 153C of the I.T. Act were applicable which exclude the application of section 147 and 148 of the I.T. Act and notice u/s. 148 of the Act and proceeding u/s. 147 are illegal and void ab initio
