Sans any adverse material, AO cannot question the wisdom and business expectancy in which wake of such evidences and record which has been duly appreciated and taken note of by the ld. CIT (A).
Pawan Hans Helicopters Ltd. Vs DCIT (ITAT Delhi) The facts in the instant case that the helicopters were acquired in 1986-87 and the assessee has been claiming the depreciation since then has not been in dispute. The AO has allowed the depreciation on helicopters in the earlier assessment years. This fact is also not disputed […]
SLV Housing Development Corporation Vs ACIT (ITAT Bangalore) The tax authorities have pointed out time gap in getting a tax audit report from a new CA. However, it is a known fact that it might have taken some time to severe relationship with the earlier CA. However, the fact remains that the tax audit report […]
Rena Sahakari Sakhar Karkhana Ltd. Vs PCIT (ITAT Pune) We find that the issue that a co-operative society would be entitled for claim of deduction under Sec. 80P(2)(d) on the interest income derived from its investments held with a co-operative bank is covered in favour of the assessee in the following cases: (i) M/s Solitaire […]
Pushp Steel and Mining Private Ltd. Vs PCIT (ITAT Delhi) The Delhi bench of the Income Tax Appellate Tribunal (ITAT) has held that the revisionary jurisdiction under section 263 of the Income Tax Act, 1961 can be exercised in a very gross case of inadequacy in inquiry by Assessing Officer subject to the pre-requirements provided […]
Randox Laboratories India Private Limited Vs ACIT (ITAT Bangalore) The facts on record reveal that the Transfer Pricing Officer under a misconception that the assessee has undertaken manufacturing activity has rejected RPM. Learned DRP has also not examined the facts in proper perspective. Rather, learned DRP has recorded an erroneous finding by stating that in […]
ACIT Vs Armee Infotech (ITAT Ahmedabad) In the case of Gujarat Ambuja (supra), the AO disallowed 25% of the bogus purchase, which has been reduced to 5% at the level of ITAT. This decision of the ITAT was challenged before the Hon’ble Gujarat High Court, the Hon’ble Court did not interfere in the finding of […]
In our considered view, the date of allotment is relevant for the purpose of computing holding period and not the date of registration of conveyance deed as held by the Hon’ble Jurisdictional High Court of Delhi in the case of K. Ramakrishnan 48 com 55
Khevana Securities and Finstock Ltd. Vs ITO (ITAT Ahmedabad) Learned AR at the time of hearing has strongly emphasized that the impugned amount represents the capital receipt on account of breach of the contract and therefore the same cannot be brought to tax. In support of his argument, the learned AR vehemently relied on the […]
Niyant Heritage Hotels [P] Ltd Vs I.T.O (ITAT Delhi) There Is no dispute that the assessee is running a resort at Raj Niwas Palace, Dholpur. It Is also not In dispute that being a tourist place, the occupancy is not throughout the year but only in seasons favourable to the tourists. Therefore, basis the revenue […]
