DCIT Vs Ozone India Ltd. (ITAT Ahmedabad) In the instant case, pursuant to amalgamation, all assets, liabilities, undertaking of the amalgamating company (KEPL) are agreed to be vested in the amalgamated company( the Assessee) as a going concern. The amalgamated company has issued 300 equity shares of its company at face value for each shares […]
ACIT Vs Himalaya Darshan Developers (Gujarat) Pvt. Ltd. (ITAT Ahmedabad) The question that arises for our adjudication whether the document in the form of tally and balance sheet found during the course of search is an incriminating document in nature. In our considered view such document are not an incriminating material, as such those documents […]
Grasim Industries Limited Vs DCIT (ITAT Mumbai) By way of this stay application, the assessee applicant has sought a stay on collection/ recovery of tax and interest demands aggregating to Rs 3,786.34 crores in respect of the dividend distribution tax (DDT), and interest thereon, under section 115O/115Q r.w.s. 2(22)(a) of the Income Tax Act, 1961, on, what […]
M/s Ace Steel Fab (P) Ltd. Vs DCIT (ITAT Delhi) In the present appeal, the only addition made in the income was of Rs.11,52,300/- on account of estimation of Gross Profit @ 68%. It is the contention of the assessee that the discrepancy in stock was due to malfunction in the ERP software. Though, this […]
Nariender Kumar Vs ITO (ITAT Delhi) It is pertinent to note that the assessee had received Rs. 1.42 crore on account of enhanced compensation of land acquisition, which included compensation of Rs. 56.90 lakhs and interest of Rs. 85.32 Lakhs. The Assessing Office had made addition of Rs. 42.66 Lakhs being 50% of interest of […]
Bharti Cellular Ltd. Vs DCIT (ITAT Delhi) It is trite that in order to reopen an assessment made under Section 143 (3) of the Act after the expiry of four years from the end of the relevant assessment year, the reasons recorded must allege that there was failure on the part of the assessee to […]
New Modern Bazaar Vs ITO (ITAT Delhi) The conditions of the allowability of expenditure is laid down u/s 37 (1) of the income tax act which speaks that any expenditure which is not a capital expenditure or personal expenses of the assessee which is laid out or expended wholly and exclusively for the purpose of […]
RBJ Infratech Pvt. Ltd. Vs ITO (ITAT Delhi) We are of the view that penalty U/s 271(1)(c) of I.T Act levied by AO has no legs to stand at present, when the corresponding additions made by the AO have already been deleted by ITAT vide its aforesaid order dated 22.12.2020 when the aforesaid quantum addition […]
Greatship (India) Ltd. Vs DCIT (ITAT Mumbai) The assessee has further assailed the disallowance worked out by the A.O under Sec. 1 4A r.w Rule 8D, on the ground that there was no recording of an objective satisfaction by the A.O that the suo-motto disallowance offered by the assessee under Sec. 14A was not correct. […]
Additions to income–Addition towards sale proceeds of the agricultural produce–Assessee produced all the documentary evidences towards ownership of land and towards carrying on agricultural activities