Protective assessment made by the Assessing Officer in the present case cannot be sustained because substantive addition has been made in the hands of IBN-18 Broadcast and therefore, if any addition is made in the present case, it will amount to double addition.
The assessee has filed its return of income on 31-12-2006 declaring total income at Rs. Nil. The assessee had claimed deduction at Rs. 1,91,400/- u/s. 80IB(10) of the income tax act. The Point of issue was the assessee has carried out the construction in violation of the original plan passed by AUDA and therefore violated the condition of section 80IB(10).
To make any disallowance under section 40A(3), it is a precondition that the assessee must have claimed deduction, directly or indirectly, for which payment is made in cash exceeding the specified limit.
Whether expenditure paid in cash, which is not disallowed u/s 37 (1), can be disallowed under section 40A(3). Whether provision of section 54F are applicable where nature of property turned into commercial purpose.
The assessee firm is a builder and developer and is assessed in the status of AOP. During the year under consideration, the assessee was developing a residential project which involved construction of 182 flats. The assessee did not disclose any income out of these projects on the plea that it was following ‘project completion method’ and offered income on these in AY 2010-11
ITAT had given a finding that the services provided to AE, Singapore cannot be equated with the kind of services provided to AE, Germany. Thus by following the order passed by the Tribunal in the hands of the assessee for AY 2006-07, we uphold the order of ld. DRP on this issue. Accordingly, the appeal filed by department is dismissed.
On facts, the Tribunal had clearly stated that the assessee had been in fact supplied the verbatim copy of the reasons, reproducing the same at paragraph 2 (page 2) of its order. The tribunal’s findings appear at paragraph 2.8 of the impugned order.
Whether the transactions between the head office in India and branch office in Canada can be considered as international transactions? The assessee had entered into certain transaction with his branch office in Canada. The AO had taken these transactions also into sweep for the purposes of making the transfer pricing adjustment.
It is well settled that the parameters of judging the justification for addition made in the assessment case of the assessee is different from the penalty imposed on account of concealment of income or filing of inaccurate particulars of income and that certain disallowance/addition could legally be made in the assessment
This is an appeal filed by assessee against the order of Ld. CIT (A) dated 18/11/2013 for the assessment year 2003-2004.The grounds of assessee was that CIT (A) did not afford the assessee sufficient time and opportunity to make necessary submission and to adduce relevant details and documents
