The facts, in brief, are that a survey u/s 133A of the Act was carried out at the business premises of the assessee. As per the Revenue, an amount of Rs. 20 lacs was accepted as undisclosed income by the assessee on account of shortage of gold ornaments weighing 758.475 gms and excess stock of silver at 91.134 kms.
In our view, offering of the so called service to a particular section as in the instant case to members of the assessee organization only does not in any way lead to a charitable activity for the purpose of sec.2(15) of the Act.
Case of the assessee is covered by sub-clause (b) of clause 2 of Circular No. 7 dated 23-10-2007 and it is also covered by clause 2(b) of Circular No. 790 dated 20.04.2000. In para 2.1 of Circular 7 dated 23-10-2007, it is clearly provided that once the amount already remitted in pursuance
Amount of advance given to M/s Dhillon Kool Drinks and Beverages Limited was advanced in the course of business. It is undisputed that the advances became irrecoverable. In such situation, as per the ratio emanating from the decision of the Hon’ble Jurisdictional High Court in the case
In the case on hand, the issue of taxability of stock option is not in dispute as the assessee himself has offered the same to tax while filing his return of income. The only issue is the amount that can be brought to tax in India.
Since there is no monetary consideration involved in transferring the manufacturing division with all its assets and liabilities under scheme of amalgamation. it cannot be considered to be a slump sale within the meaning ascribed under section 2(42C)
Deemed dividend (to extent of accumulated profit) includes, Any payment by way of loan or advance by a closely-held company to a shareholder holding substantial interest. Such deemded dividend is treated as Income From Other Sources (IFOS) in the hand of such shareholder.
Facts of the case show that the assessee filed return of income declaring net income of Rs. 24,14,640/- electronically on 21.10.2007. The return was processed u/s. 143(1) of the I.T. Act. The assessee noticed that credit for advance tax of Rs. 1,10,000/- and TDS of Rs. 5,38,560/- was not allowed to the assessee.
The dispute is regarding treating the assessee in default u/s 201 (1) and consequential levy of interest u/s 201 (1A) for failure to deduct TDS in respect of amounts payable to M/s Overseas Shipbuilding Cooperation Centre in connection with consultancy work.
In the instant case, all the shares have been bought by the assessee in the regular course of his business, employing common funds, depositing them in the same D-Mat account, and even through the same broker and infrastructure.
