Tek Chand Vs ITO (ITAT Chandigarh) The A.O. obtained the approval of the PR. CIT before issuing the notice under section 148 of the Act. The proposal dt. 11/03/2016 seeking the approval for issuance of notice under section 148 of the Act, by the A.O. is placed at page no. 2 & 3 of the […]
Barnala Steel Industries Ltd Vs ACIT (ITAT Delhi) Consolidated Issue of Notice In Search Case For Different Assessment Years Makes Entire Assessment Order Invalid We have heard both the parties and perused all the relevant material on record. From the perusal of the notice issued u/s 153A r.w.s. 153C/143(2) of the Act, it is a […]
Chandrakant R. Agrawal Vs PCIT (ITAT Mumbai) At the first blush the claim of the assessee for setting off the interest paid on the loan raised (on security of the FDR’s) against the interest received on FDR’s appeared to be very convincing. However, we find that the issue is no more res integra and had […]
Srabani Constructions Pvt Ltd. Vs ACIT (ITAT Cuttack) In the present case, the AO has made addition of Rs.1,68,54,180/ @ 15% by considering whole amount of advance from customers i.e. closing balance as on 31.3.14 of Rs.11,23,61,227/-, which also includes opening balance from customers brought forward from earlier year as opening balance as on 1.4.2013 […]
Visakhapatnam Port Trust Vs CIT (ITAT Visakhapatnam) In the instant case, the registration was already granted by the Ld.CIT vide order dated 20.03.2008 w.e.f. 01.04.2002. There is no dispute with regard to genuineness of the activities and there is no finding of the Ld.CIT with regard to not carrying on the activities as per the […]
USG Buildwell Pvt. Ltd. Vs Additional CIT (ITAT Delhi) The Ld. DR submitted that the disallowance u/s 37 on account of additional payment for purchase of land was righty made as the assessee could not establish his case as the expenditure was incurred without any substantial evidence produced before the Assessing Officer to that effect […]
Sunrise Jewellers Vs ITO (ITAT Cuttack) Addition of Rs. 1,19,848/- on ad hoc basis without specifying/pinpointing which voucher is not verifiable After hearing both the sides and perusing the entire material available on record along with the paper book filed by the assessee as well as the orders of the authorities below and the written […]
Ram Niwas Agarwal Vs ITO (ITAT Bangalore) It is not in dispute that if the ratio laid down by the Hon’ble Karnataka High Court in the case of Fateeraj Singhvi (supra) is applied then the levy of interest u/s.234-E of the Act would be illegal for returns of TDS in respect of the period prior […]
UL India Pvt. Ltd. Vs DCIT (ITAT Bangalore) The next issue relates to the addition made rejecting the claim of change in method of revenue recognition. The Ld A.R fairly admitted that this issue has been decided against the assessee by the co-ordinate bench in AY 2009-10 (referred supra). We notice that this issue has […]
Sungrow Impex Private Limited Vs ITO (ITAT Delhi) Conclusion: CIT had recorded his satisfaction for reopening of the assessment in a most mechanical manner without considering even the assessment records or the return of income filed by assessee and his satisfaction appeared to be in a ritualistic and formal rather than meaningful. Therefore, such approval […]
