Learned counsel for the assessee submitted that it is a case of frivolous double addition on deliberate misconception of the facts. He took us through the year-end financial statements of the assessee and its computation of income to demonstrate that the impugned addition
The assessee has shownexpenditure on advertisement through outdoor display which includes payment for advertisement on hoarding/board. The A.O. further noticed that the assessee has deducted TDS @ 2% u/s.194C on these payments.
In the assessment order passed u/s.144 the income was at Rs.12,96,457/- as against the returned income of Rs.1,20,000/-. During the course of assessment proceeding, the AO found that there was a cash deposit of Rs.11,76,457/- in the bank account of the assessee maintained with ICICI Bank.
The assessee entered into an agreement with an Export House M/s Rajnikant & Bros. As per the terms of the agreement M/s Rajnikan & Bros imported consignment of “Almonds in Shell” at Madras Port. This import was actually for one of the nominee of the assessee M/s Peanut Products
Assessee engaged in the business of real estate and construction had filed its return for AY; 2009-10 declaring an income of Rs.55,45,092/-and for AY: 2010-11 and an income of Rs.8,07,253/-. During the course of assessment proceedings
The facts, in brief, are that the assessee declared net wealth of Rs.2,75,28,460/- in his wealth tax return. The ld. Assessing Officer accepted the wealth declared by the assessee by passing an order u/s 16(3) of the Wealth Tax Act, 1957.
No addition can be sustained in this case, as, neither there is any investigation whatsoever made by the Assessing Officer nor was any evidence gathered by him. Merely because the market value as per the stamp valuation authorities and the sale price are at variance, no addition can be made to the business income.
It is settled law that that frequency and magnitude of transaction are also important factor to decide whether the transaction is business transaction or investment transaction. Now in our considered opinion, the magnitude of share transaction in this case does call for any enquiry
The assessee is a FUND and a resident of Denmark. Along with its return of income, in India, the assessee had submitted ‘Tax Residency Certificate’ issued by the Danish Authorities in order to claim the benefit of Article 14 of India-Denmark DTAA.
First contention of the assessee is that the sale consideration cannot be taken more than the actual sale consideration shown in the transfer deed i.e. a sum of Rs.4 1.51 crores. The alternative contention is that if the sale consideration is taken as valuation done by the Stamp Valuation Authorities then there is a mistake
