ITAT Delhi held In the case of ACIT vs, M/s Amrapali Grand that before a notice under Section 153C can be issued two steps have to be taken. The first step is that the Assessing Officer of the person who is searched must arrive at a clear satisfaction that a document seized from him does not belong to him but to some other person.
Pfizer Ltd Vs ACIT (ITAT Mumbai) The CBDT had issued Circular No.681 dated 8th March 1984 providing that a contract undertaken to supply any article or goods according to the specifications given by any person
In the case of Vofafone East Ltd. Vs. Addl. CIT Kolkata Bench of ITAT observed the applicability of various provision of TDS where tax was not deducted on the roaming charges paid by the Appellant to its telecom operators.
In the case of ACIT Vs. Prem Castings Pvt. Ltd. ITAT, Delhi Bench reversed the order of CIT (A) who deleted addition of Rs. 3,46,00,000/- after relying upon the decision of Hon’ble SC in the case of Lovely Exports (216 CTR 195) in which it was held that once the assessee has produced documents regarding
In the case of ACIT vs. OBC, Mumbai Bench of ITAT observed that the amount paid by the assessee bank (the lessee) to City Industrial Development Corporation (MMRDA) (Lessor) was in the nature of rent as defined u/s 194 I of the Act or not, which held yes by CIT (A).
ITAT Delhi held In the case of Xchanging Technology Services India Private Limited. vs, DCIT that the Hon’ble High Court affirmed the conclusion that a captive unit of a comparable company which assumed only a limited risk cannot be compared with a giant company in the area of development
ITAT Delhi held In the case of Eli Lilly & Co. (India) Pvt. Ltd. vs, ACIT that a clear distinction has been made between the free samples, gifts, travel facilities, hospitality and cash or monetary grants. It would accordingly be incorrect to put samples in the definition of gifts being separately categorized
ITAT Delhi held In the case of Tsurphu Labrang vs. DIT (Exemptions) that Rule 17A itself provides that it is not necessary that the Institution/Trust should be established under an instrument. The Rule 17A does not prescribe that in case the Institution/Trust
ITAT Delhi held In the case of Honda Trading Corporation. vs, DCIT that despite the use of the word `may’, the time limit for passing the order by the TPO is mandatory, as in the otherwise situation of the TPO having been allowed more time by implication
ITAT Delhi held In the case of Alcatel-Lucent Technologies. vs, DCIT that merely because the assessee in the TP study had included the comparable, which was accepted by TPO, it does not follow that the assessee cannot resile from its original claim at a later stage of proceeding
