DSIIDC Ltd. Vs PCIT (ITAT Delhi) It is pertinent to note that the Assessing Officer has raised only a query before completion of assessment u/s 143 (3) relating to claim of 80IA(4). However, the Assessing Officer has not given any cogent finding. Thus, the observation of the Principal Commissioner of Income Tax that the assessment […]
Green Park Estate Pvt. Ltd. Vs ACIT (ITAT Delhi) A perusal of the reasons recorded in the case of the assessee as well as in the case of M/s Green Valley Tower Ltd. are identical on the issue of alleged interest paid on post dated cheuqes. We have also gone through the paper book containing […]
ITAT find that order u/s 263 passed by PCIT dwelled into the issue of re-computation of capital gains which is beyond the mandate of limited scrutiny issued by CBDT. Hence, directions of PCIT are beyond selection criteria of scope of scrutiny for instant year cannot be held to be legally valid.
ITAT held that in case A comparable having an extraordinary financial event of Merger and Acquisition (M& A) during the year the same cannot be considered as functionally comparable for transfer pricing (TP) comparability analysis.
Mobileum Inc Vs DCIT (ITAT Mumbai) since transactions between the assessee and its AE have been found at arm’s length prices no further income chargeable to tax in India can be said to be attributable for the PE of the assessee. FULL TEXT OF THE ORDER OF ITAT MUMBAI This appeal by the Assessee is […]
DCIT Vs Singhania Buildcon Pvt. Ltd. (ITAT Raipur) 1. AO has not made any attempt to rebut the claim of the assessee. The confirmations were filed by the assessee to support the factual position. The assessee has placed the facts which are apparent in nature for which no rebuttal has been done. 2. The Hon’ble […]
Resale Price Method (RPM) To Be Preferred As The Most Appropriate Method, Where The Transaction With Associated Enterprise (AE) Relates To Import of A Product For Resale To An Unrelated Party.
Internal Comparable Uncontrolled Price Method (CUP) to be preferred as the Most Appropriate Method over External CUP, where direct internal comparable price is available.
Shri Sanjay Singal Vs DCIT (ITAT Chandigarh) Addition of Rs. 61.86 Crore in 9 Appeals on Account of Bogus Long Term Capital Gain U/S 10(38) Claimed Deleted on Facts of Alleged Penny Scrip of PIL (Praneta Industries Ltd) and Revenue Rule 29 Application Containing Fir Filed by ED Against Companies of Bhushan Group & Statement […]
For the condonation of the delay, the assessee has to show that there must be a sufficient cause to condone the delay. In this case, the assessee himself decided as per his affidavit not to go to his house knowingly that there must be an assessment order. No one is prevented the assessee to go to his house therefore, we are of the opinion that there is no sufficient cause to condone delay. Accordingly, the appeals filed by the assessee are dismissed.
