ITO Vs Shri Sunil Govind Agre (ITAT Mumbai) During the course of assessment proceedings, the AO called for information u/s 133(6) from the above two parties in order to verify the genuineness of transactions. However, the notices sent by him could not be served and these were returned un-served by the postal authorities with the […]
IBM India Pvt. Ltd. Vs ACIT (ITAT Bangalore) It has been submitted by Ld.Counsel that as a consequence of APA entered into by assessee, income was increased vis-a-vis original computation at page 322. Referring to revised computation at page 328 of paper book volume 1, he submitted that, incremental increase in the income is Rs.7,74,2 […]
Bureau Veritas Consumer Products Services (India) Private Limited Vs ACIT (ITAT Delhi) ITAT held that It is true that the assessee has paid rebate/discount to its overseas AEs. It is equally true that such arrangement has been done through Master Service Agreements (‘MSA’) with various overseas companies (sample JC Penny ) for providing testing and […]
ITO Vs Manoj Vashudev Wadhwa (ITAT Mumbai) In ACIT v. Vireet Investment (P.) Ltd. 165 ITD 27 (Del) (SB) it is held by the Special Bench of the Tribunal that only those investments are to be considered for computing average value of investment which yielded exempt income during the year. We are of the considered […]
Next Gen Films Private Ltd. Vs ITO (Int. Tax-TDS) (ITAT Mumbai) Regarding commissioning agreement entered into by the assessee (Next Gen Films Private Ltd.) with M/s DBPL, at para 2.12, we reached a conclusion that the contract between the assessee and M/s DBPL (M/s Desi Boyz Production Ltd. ) was primarily on principal-to- principal basis. […]
Chowdry Associates Vs ACIT (ITAT Delhi) From the entirety of the events, we find that in the assessment year 2014-15, the assessee had made purchases in the middle or last week of June 2013 through M/s Anand Rathi Commodities Ltd. and M/s Philips Commodities Pvt. Ltd. The NSEL failed to fulfill its commitments and ultimately […]
Microsoft Corporation (India) Pvt Ltd Vs DCIT (ITAT Delhi) The issue under consideration is whether expenditure on account of civil and interior works liable for depreciation at 10% or at 15%? ITAT states that, they have perused the items of the expenditure which has been reproduced by the assessing officer in the assessment order and […]
The issue under consideration is whether Section 41(1) is applicable in case of waiver of liability incurred in respect of purchase of capital asset?
The issue under consideration is whether the assessment order passed by the assessing officer under section 153C is bad in law and void ab-initio?
DCIT Vs DHL Logistics Pvt. Ltd. (ITAT Mumbai) The issue under consideration is whether assessee is eligible for Depreciation on Goodwill resulting from acquisition of business unit? ITAT states that the issue as regards the entitlement of the assesses towards claim of depreciation on intangible (i.e goodwill) is squarely covered by the orders of the […]
