Arjun Transport Company Private Limited Vs ITO (ITAT Mumbai) When a case is selected for ‘limited scrutiny’ to verify the disallowance made u/s 14A of the Act and AO makes disallowance u/s 14A in the assessment order passed u/s 143 of the Act then the CIT(A) cannot travel beyond the issue selected under ‘limited scrutiny’ […]
HCL Comnet Ltd. Vs DCIT (ITAT Delhi) It is settled principle of law that generic dissatisfaction as to the correctness of the claim of the assessee without assigning any reason is not a valid satisfaction which is mandatory under section 14A(2) of the Act, as has been held by Hon’ble Supreme Court in case of […]
Supertech Forgings (India) Pvt. Ltd. Vs DCIT (ITAT Amritsar) No addition in respect of bogus Purchases can be made during the year under consideration No addition in respect of bogus Purchases can be made during the year under consideration where the purchases made from the same parties have been accepted in subsequent year by Department. […]
Jindal Aluminium Limited Vs DCIT (ITAT Bangalore) We have heard rival submissions and perused the material on record. The Hon’ble Apex Court in the case of Bharat Commerce & Industry v. CIT reported in 230 ITR 733 had held that interest for late payment of direct taxes is not a deductible expenditure. In view of […]
ITAT Delhi upholds addition of Rs. 18.75 crore as deemed dividend in Anil Nanda’s case, citing substantial shareholding and indirect benefits. Appeal dismissed.
ITO Vs Gujarat Storages P.Ltd. (ITAT Ahmedabad) As far as banking transactions are concerned, these details were available with the AO. This information was given in the audited accounts. Any transactions shown in the bank statement could never be construed per se as an escaped income. It is the AO who has to form his […]
Addl. CIT Vs Airports Authority of India (ITAT Delhi) Perusal of the order passed by the ld. CIT (A) shows that the ld. CIT(A) deleted the penalty on two grounds : (i) that no valid notice u/s 274 of the Act has been issued to the assessee so as to inform the assessee as to […]
3M India Limited Vs CIT (LTU) (ITAT Bangalore) A perusal of the same would show that the assessee is making year end provision every year. The provision made in one year is reversed in the succeeding year. There is no dispute that the assessee has voluntarily disallowed the year end provision u/s 40(a), since no […]
HCL Technologies Ltd. Vs DCIT (ITAT Delhi) Levy of penalty in this case is unsustainable because mere preferring a claim which is unacceptable to the Revenue does not ipso facto lead to levy of penalty. Here in this case, Form No. 56F duly signed by the Chartered Accountant justifies the plea of bona fide belief […]
Union Bank of India Vs DCIT (ITAT Mumbai) We find that AO has withdrawn, the relief granted u/s. 14A in the assessment order by mentioning that subsequently order of Hon’ble Supreme Court in Maxopp Investment Ltd. 402 ITR 640 has come. Accordingly, he has effectively made the disallowance us/.14A u/s 154 of the Act. We […]