Where the assessee diverted borrowed funds towards investment in a company but did not collect any interest on money so invested then the AO was justified in making the disallowance of interest on borrowed capital particularly in view of the fact that the assessee failed to prove that there was any commercial expediency in making the investment that company.
Amadeus India challenges ITAT Delhi’s transfer pricing adjustment on AMP expenses and disallowance under section 14A. Full text of the ITAT order provided.
Atul Dinesh Seth Vs ITO (ITAT Bnagalore) The contention of the A.R. is that once the income of the assessee estimated by applying the section 44AF of the Act, there cannot be any further addition for any lapse in the books of accounts. In these assessment years, except AY 2011-12, the turnover of the assessee is […]
Yokogawa India Ltd. Vs ACIT (ITAT Bnagalore) Admittedly the impugned assessment order passed by the Ld.AO under section 143 (3) read with section 144C is in violation mandatory provisions under section 144C(10) and (13) of the Act by not passing the order in pursuance of and in conformity with the directions of DRP issued under […]
Uber India Systems Private Limited Vs Jt. CIT (ITAT Mumbai) Uber B.V. is involved in rendering lead generation service to the Driver-Partner and transportation service is not provided by Uber B.V. or UISPL. The transportation service is provided by the Driver- Partner to the User for which the car is arranged by the Driver-Partner, all […]
DCIT Vs Realistic Realitors Pvt. Ltd. (ITAT Delhi) In this case the A.O. in the light of information emanating from the search of Shri Praveen Agarwal came to the conclusion that assessee has wrongly claimed deduction on account of sub-brokerage paid to M/s. Taral Vincom Pvt. Ltd., The A.O. in the entire assessment order did […]
ACIT Vs IKEA Trading (India) Pvt. Ltd. (ITAT Delhi) We find that the assessee has sold assets at the WDV of the assets as per company law whereas the TPO held that the assessee ought to have sold the assets at the value of the WDV of the block of assets as per the Income […]
DCIT Vs GHCL Ltd. (ITAT Ahmedabad) During the course of assessment, the assessee has submitted that foreign exchange gain/loss should be considered as part of operational income mainly stating that receipts/expenditures are booked at the time of transaction while conversion of payment/receipts of foreign exchange occurs at a later point of time resulting into foreign […]
DCIT Vs Charotar Gas Sahakari Mandali Limited (ITAT Ahmedabad) Briefly stated, the assessee is a co-operative society and engaged in providing CNG Gas and purchase and sale of natural gas to domestic and commercial consumers and earns commission on CNG. In the course of the scrutiny assessment, the AO observed that a revised return was […]
Smt. Sarika Mittal Vs ACIT (ITAT Jabalpur) It is not in dispute that the AO in all the cases is of the rank of the Assistant Commissioner, i.e., below the rank of the Joint Commissioner. Similarly, the year of search being f.y. 2009-10, all the assessment years under reference, i.e., AYs. 2004-05 to 2010-11, are […]
