Manash Nandi Vs ITO (ITAT Kolkata) We find that the AO has recorded the reasons u/s 148 of the Act in a very casual manner. We find that the AO has only reproduced in the reasons recorded the information received and hurriedly came to the conclusion that there exists escapement of income and evasion of […]
A. Johnkuma Vs DCIT (ITAT Chennai) Facts- The assessee, a Proprietor of M/s. A.Johnkumar Cost Price Shop and M/s.Johnkumar Real Agency, is engaged in the business of running a Departmental Store and real estate business respectively. A search and seizure operation was conducted u/s.132 of the Act, on 17.09.2016. During the course of search, a […]
Capgemini India Pvt. Ltd. Vs DCIT (ITAT Mumbai) Facts- Assessee filed its return of income on 7 October 2010 declaring income of ₹113,19,82,875/-. As the assessee has entered into several international transactions, reference was made to the Learned Additional Commissioner of Income-Tax, Transfer Pricing, 1(3), Mumbai for determination of arm’s length price of those transactions. […]
Salarpuria Properties Pvt. Ltd. Vs DCIT (ITAT Kolkata) Facts- The assessee has filed ROI on 9.10.2010 which was revised on 27.12.2010. The return was processed u/s 143(1) of the Act accepting the returned income. Thereafter the case of the assessee was selected under scrutiny and statutory notices were duly issued and served upon the assessee. […]
Held that imparting of ‘education’ in the field of architecture is covered within the provisions of section 2(15) of the Act and hence eligible for exemption under section 11 of the Income Tax Act
Section 68 of the Act creates a legal fiction which cast obligation on the assessee to explain to the satisfaction of the AO about nature and source of credit in case any amount is found credited in the books of the assessee maintained for any previous year.
Sanjay Subhashchand Gupta Vs ACIT (ITAT Mumbai) As per the provisions of section 2(22)(e), loan or advance paid by a company shall be considered as deemed dividend on fulfillment of following conditions (i) the company must be a company in which the public is not substantially interested; (ii) such a company has given advance or […]
DCIT Vs Indranil Sanjaybhai Rajyaguru (ITAT Rjakot) It is an undisputed fact that when the initial payment of Rs. 12.15 crores has been made for purchase of the new asset that too more than the amount of capital gain to the tune of Rs. 2.90 crores before the due date of filing of the return […]
ESPN Digital Media (India) Pvt. Ltd Vs DCIT (ITAT Chennai) ITAT held that the consideration paid by ESPN India for purchase of advertisement space was not taxable during the period under consideration. The consideration paid by ESPN India is not for ‘use’ of equipment (server) or for any process nor imparting of any information concerning […]
Ajeet Singh Vs ITO (ITAT Jaipur) ITAT held that the amendment brought in the statue i.e., by Finance Act, 2021, the provisions of Section 36(1)(va) r.w.s. 43B of the Act amended by inserting explanation 2 is prospective and not retrospective. Hence, the amended provisions of Section 43B r.w.s. 36(1)(va) of the Act are not applicable […]
