ACIT Vs. V. V. Rajam (ITAT Hyderabad) AO has observed that the assessee has purchased a land of 2 acres in survey No. 356/3E1/1 situated at Pragnyapur village, Gajwel Mandal, Medak District in his name for a consideration of ₹ 1.2 crore as well as purchased a house in Hyderabad in his wife’s name for […]
Sukhdev Singh Vs ITO (ITAT Delhi) As regards the contention of notice not properly served by the Assessing Officer, the explanation of the postal authorities is that the assessee has refused to take notice is a good service and hence ground Nos. 1 to 7 are dismissed. As regards ground Nos. 8 to 13, the […]
Morgan Stanley Mauritius Co Ltd Vs DCIT (ITAT Mumbai) The reasoning given by the DRP is ex facie incorrect inasmuch as the SCB-India, being a permanent establishment of a company fiscally domiciled in the United Kingdom, and is not a taxable unit in India, and the taxability is in the name of its general enterprise- […]
The property was conveyed to assessee after the death of his father in 1955, i.e. before coming into force of Hindu Succession Act, 1950. Accordingly, the property belonged to HUF of assessee and not to assessee-individual. Therefore, the assessment order passed under section 147 for difference in sale consideration and fair market value of property itself was liable to be quashed.
Merely because assessee had not disclosed mode of payment of salary i.e. either by cheque or cash, the same should not doubted especially when such salary to security guards came to Rs.27,000/- per month for four persons. Even, if the payment was made in cash, there would be no violation of section 40A(3).
Manoj Singhal Vs PCIT (ITAT Delhi) On going through the details, we find that the deduction claimed u/s 54F was Rs.6,12,10,100/- whereas the deduction eligible was Rs.6,11,19,500/-. Thus, there is a computational difference of Rs.90,600/- in the claim of deduction u/s 54F which could have been rectified u/s. 154. The provisions of section 263 need […]
Smt. Bachupally Laxmi (alias Routhu Laxmi) Vs ITO (ITAT Hyderabad) For the purpose of computation of LTCG arising out of the development agreement cum GPA, the Assessing Officer has accepted that the assessee has acquired the flats as on 9.11.2009 and therefore, in the year 2012 when the assessee has sold the flat, the holding […]
Goldman Sachs (India) Finance Private Limited Vs DCIT (ITAT Mumbai) We are of the considered opinion that in this regard if the assessee is not called upon to pay any tax on book profit as taxes on normal computation are higher even after the aforesaid exercise of increase of the book profit by the amount […]
International Air Transport Association (Canada) Vs ACIT (ITAT Mumbai) At this stage, we may herein observe that as in the present case before us, in the case of Delmas France (supra) also there was no finding of the lower authorities that the transactions between the principal and agent were done in arm’s length conditions. Under […]
ACIT Vs Yashovardhan Tyagi (ITAT Delhi) he issue in the present ground is with respect to the addition of Rs.20,00,000/- made u/s 69A of the Act. AO made the addition u/s 69A of the Act and treated the amount of Rs.20,00,000/- from M/s. Eagle Home Entertainments Pvt. Ltd. to be as not recorded in the […]
