ITAT Jaipur held that assessment which are already completed after making proper inquiries cannot be allowed to again reframed merely based on the search without any fresh evidence. Addition unsustainable
ITAT Bangalore held that in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur advertisement, marketing and promotion (AMP) expenses, the same cannot be regarded as an international transaction at all and hence TP adjustment not sustainable
ITAT Hyderabad held that payment of remuneration to the trustees could result into disallowance of excess expenditure and the same cannot be a ground to cancel the registration of trust
ITAT Ahmedabad held that addition solely on the basis of investigation wing report unsustainable as onus was discharged by the assessee as PAN card and bank statements were duly submitted
ITAT Bangalore held that expression expenditure also includes loss and therefore the difference between the price at which the shares are issued to the employees and the market value of the shares would be expenditure incurred for section 37(1) of the Income Tax Act
Assessee had given the scientific basis for the warranty in respect of tyres sold to the truck segment and non-truck segment and further the issue was pending with the AO because AO had to verify the details in term of the decision of the Supreme court in the case of Rotork Controls India Pvt. Ltd., vs. CIT,314 ITR 62(SC). Therefore, the matter need to go back to the file of AO.
Integra Engineering India Ltd. Vs ACIT (ITAT Ahmedabad) It is pertinent to note that though the assessee has stated that the intention of the assessee to give advances to its subsidiary for making capital and subsidy but the intention was to control the operation of the GTL and to oversee that the manufacturing cost of […]
Income from assets given on lease, though offered to tax under normal provisions, was not routed through Profit and Loss Account and the accounting treatment given by assessee was in accordance with mandatory AS-19 which mandated assessee to reflect investment in asset under finance lease as lease receivable in balance-sheet on asset side under the head loans and advances.
Raghavendra Lorry Services Vs DCIT (ITAT Visakhapatnam) We find from the order of the Ld. AO, the Ld.AO has followed the directions of the CIT and has estimated the income @ 15% on the gross receipts without allowing the depreciation. It was also found from the submissions of the Ld. AR that the assessee a partnership […]
As entire amount is debited to the Profit and Loss account and accounted in the regular books of accounts, the same cannot be disallowed under Section 69C