Yeshoda Electricals Vs ACIT (ITAT Bangalore) This notice issued u/s. 148 is a manual notice and not a digital document. The digital document only does not require signature. A manual notice u/s. 148 is required to be dated and duly signed by the Officer who is issuing the same. A notice or an order without […]
Lam Research (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore) It was submitted that Working capital adjustment is made for the time value of money lost when credit time is given to the customers. The Assessee however does not bear any risk and has no working capital contingencies. The Assessee has not incurred any expenses for […]
Asian Paints Ltd Vs ACIT (ITAT Mumbai) We have considered rival submissions in the light of decisions relied upon and perused material on record. Undisputedly, the assessee in its computation of income has computed disallowance under section 14A of the Act at Rs.23,98,769 by applying certain principles of apportionment. Therefore, it is not a case […]
P. Venkata Ramana Reddy Vs ACIT (ITAT Hyderabad) CBDT Circular mentions that the concerned assessees should be intimated that their cases fall either in ‘Limited Scrutiny’ or ‘Complete Scrutiny’ through notices issued u/s 143(2) of the Act and the procedure prescribed is that in Limited Scrutiny cases, the reasons/issues shall be forthwith (emphasis provided by […]
Bhagyalaxmi Conclave Pvt. Ltd. Vs DCIT (ITAT Kolkata) In the remand report, the AO clearly stated that notice u/s 143(2) of the Act was issued by DCIT, Circle-1, Kolkata. The ld. D/R could not controvert the contention of the assessee that no notice u/s 143(2) of the Act was issued by the DCIT-13(1), Kolkata, who […]
DCIT Vs DLF Assets Pvt Ltd. (ITAT Delhi) The assessee is without doubt a Developer of a SEZ, having been in fact allowed deduction u/s.80-IAB on it’s other income/s, as from service agreements, chargeable u/s. 28. That the said income is assessable as business income, and only rightly so, inasmuch as the source thereof is […]
DCIT Vs Jateen Madanlal Gupta (ITAT Ahmedabad) On perusal of the reasons recorded by the AO, we find that the AO at the threshold has recorded that it is seen that the assessee is having substantial share in ‘JPIL’ which has advanced loan to the companies namely M/S Gujarat Mall Management Pvt. Ltd, and M/S […]
Shishir Kumar Das Vs DCIT (ITAT Hyderabad) Decision of the Hon’ble Supreme Court in the case of CIT vs. Alom Extrusions Ltd is applicable to both the employer as well as employee’s contribution to Provident Fund and ESI and if the assessee has not remitted the amount collected from the employees before the due date […]
Sheela Yogi Vs ITO (ITAT Jaipur) Once the summons have been issued and these persons have appeared and given their statements before the AO wherein they have confirmed that they have advanced the amount to the assessee towards purchase of the agricultural land and has also disclosed the source of their earnings/savings, the assessee has […]
Bharat Rasayan Ltd. Vs ACIT (ITAT Delhi) We have also examined the para no. 3.15.3 of the scheme document of the Foreign Trade Policy of Government of India, Ministry of Commerce and Industry wherein it was specified that market linked focus products scripts (MLFPS) is meant for export of products of high export intensity employment […]