Indraprastha Shelters Pvt. Ltd. Vs DCIT (ITAT Bangalore) With regard to the other reason given by the revenue authorities for denying deduction of interest paid to Mrs.Kaveri bai is by applying the 3rd proviso to Sec.24(b) of the Act. On perusal of the provisions of section 24(b), it is clear that the deduction is allowed […]
Bombay Rayon Holdings Ltd. Vs ITO (ITAT Mumbai) Another issue in this regard for A.Y.2010-11 onwards is that the loan has been converted into share application money. In this regard, the ld. Counsel of the assessee has placed reliance upon several case laws that share application money is shareholder fund and no interest should be […]
DDIT Vs Mitsui & Co. Ltd. (ITAT Delhi) Learned DR contended that MIPL is economically dependent on assessee company as major revenue of MIPL is from assessee company. We are of the view that this per se cannot be ground to hold that MIPL is a Dependent Agent. For invoking this clause, first one of […]
Dart Infrabuild (P) Ltd. Vs ITO (ITAT Delhi) A conjointly reading of section 148 (1) of the Act with section 139 (4) of the Act and section 144 of the Act makes it abundantly clear that pursuant to the notice under section 148 of the Act, if an assessee files a belated return or letter […]
ITAT Mumbai: Anil K. Shah’s appeal against reassessment. Challenges various additions including expenses, borrowed funds, and alleged bogus purchases. Legal and evidential arguments presented.
Toyoda Micromatic Machinery India Private Ltd. Vs DCIT (ITAT Delhi) It is a fact that the learned assessing officer has not challenged the order of the learned CIT – A stating that resale price method is the most appropriate method as assessee does not engage in any deemed manufacturing or further value addition. It is […]
Google India Private Limited Vs JCIT (ITAT Bangalore) By this Stay Petition, the assessee is seeking to stay the recovery of outstanding tax arrears of Rs.1260,56,49,209. 2. Originally the stay was granted vide the order dated 20.11.2019 of the Tribunal in SP No. 293/Bang/2019, for a period of six months. As per the original stay […]
Where assessee-trust was collecting fees from different organizations towards training programmes and it also received rent for letting out its part premises; the CIT was justified in rejecting the assessee s application for grant of registration under section 12AA on the ground that the activities of the trust were not charitable, but were commercial in nature.
Minimum guarantee amount which was paid by the distributor for acquiring the exhibition rights of a movie was a fixed expenditure for the distributor that was paid to producers irrespective of the fact whether the film generated a profit or incurs losses. Hence, the payments made by assessee did not fall under the term Royalty and did not attract the provisions of TDS.
Provision for software expenses could not be disallowed by considering it as contingent liability as assessee was required to make provision for all known liabilities and losses as per accounting standards prescribed by ICAI and also by the Central Government under the Income Tax Act even though the amount could not be determined with certainty.
