Pooja Marketing Vs. Pr. CIT (ITAT Mumbai) In the present case before us, the assessee had offered its entire income including income by way of winnings from lotteries on unsold lottery tickets, as income chargeable under the head ―Profits and gains of business or profession“. However, the ld PCIT had sought to treat the income […]
ACIT Vs. K. S. Chawla & Sons (HUF) (ITAT Delhi) > HELD THAT:- In the present assessee’s case, search & seizure action u/s 132 of the Act was carried out on 15.10.2009 in the premises of Mr. Abhinav Arora and Mrs. Ranju Arora. Consequently, the Assessing Officer initiated reassessment proceedings u/s 147 of the Act […]
Ganpati Zilla Krishi Audyogik Sar Seva Sahakari Society Ltd. Vs ITO (ITAT Pune) The contention of Ld. AR that a Review petition has been filed before the Hon’ble Supreme Court against the judgment in the case of CIT Vs Tasgaon SSK Ltd. (2019) 412 ITR 420 (SC) which is still pending and hence the decision […]
Ropar Properties And Builders Pvt. Ltd. Vs ITO (ITAT Chandigarh) To convert the limited scrutiny into complete scrutiny, the Assessing Officer shall be required to form a reasonable view that there is a possibility of under statement of income and that view should be based on credible material or information available on record and such […]
Bajaj Sons Ltd. Vs DCIT (ITAT Chandigarh) We find that a separate surrender of Rs. 97.11 lacs has been made by Shri SB Bajaj Director of the assessee company on account of unexplained cash found during the search action. However, so far as the surrender of Rs. 15 lac to cover any discrepancy is concerned, […]
Merely saying that `loan had been advanced’ or `ITR had not been filed’, without disclosing the reasons, which led AO to hold such a belief , did not confer valid jurisdiction on the AO to take action u/s 147 and 148.
Building Committee (Society) Barnala Vs CIT (Exemption) (ITAT Chandigarh) It is pertinent to observe that the ld.CIT(E) failed to comprehend the role of Bar Association in judicial dispensation. He construed the existence of the assessee-society in a very narrow manner, as if it is a group of some professionals who are working for their individual […]
Shri Shyam Sunder Infrastructure (P) Ltd. Vs ITO (ITAT Delhi) Conclusion: Since assessee produced sufficient documentary evidences before AO to prove the identity of the Investor Companies, their creditworthiness and genuineness of the transaction and no evidence had been brought on record by AO to disprove the same, hence addition made under section 68 was […]
Dow Agrosciences India Private Limited Vs ACIT (ITAT Mumbai) We shall now deal with the observation of the TPO/DRP that the approval provided by the RBI would not constitute a valid CUP data, since the RBI does not take into account the transfer pricing provisions to determine the appropriate rates which can be considered as […]
Batliboi Limited Vs DCIT (ITAT Mumbai) Assessee has received total sum of Rs.11,14,00,000/- from single purchaser on sale of land (Rs.5,72,84,600/-), towards building (Rs.64,90,400/-) and sale of additional FSI (Rs.4,76,25,000/-). We find that the total sale consideration of Rs.11.14 Crores has not been doubted by the Revenue. Admittedly, the aforesaid break-up of consideration has been […]
