JCIT (LTU) Vs M/s. Texas Instruments (India) Pvt. Ltd. (ITAT Bangalore) As per the submissions made by Ld A.R, we notice that the disallowance of Rs.5.54 crores made by the AO forms part of Provision for expenses amount of Rs.9.71 crores created on 31.3.2006 relevant to AY 2006-07. It was submitted that the above said […]
M/s. Innaccel Technologies Private Ltd. Vs ACIT (ITAT Bangalore) The A.O. was of the view that the shares of the company have been over valued and accordingly asked the assessee to justify the valuation. After considering the explanations of the assessee, the A.O. took the view that the valuation report has been prepared on the […]
DCIT Vs Coffeeday Enterprises Ltd (ITAT Bangalore) In terms of section 195, the liability to withhold taxes arrears at the time of payment/credit of any interest (or any other sum) which is chargeable under the provisions of the Act. The payment/credit was not made till 31.03.2010 and also in terms of the Agreement, interest was […]
Where AO made addition under section 68 based on third party statement recorded by investigation wing, however, without affording opportunity of cross-examination to assessee, it amounted to violation of principles of natural justice and, therefore, addition was deleted.
ITAT Kolkata quashes arbitrary disallowance by AO. Ambuja Housing wins against DCIT. Get insights into the judgment on Rule 8D and 14A.
Nikon India Pvt. Ltd. Vs DCIT (ITAT Delhi) Section 154(1A) lays down that rectification can be done for any matter other than the matter considered and decided in appeal/revision. Thus, whene any matter had been considered and decided in any proceeding by way of appeal or revision, rectification of such matter cannot be done by […]
Indraprastha Shelters Pvt. Ltd. Vs DCIT (ITAT Bangalore) With regard to the other reason given by the revenue authorities for denying deduction of interest paid to Mrs.Kaveri bai is by applying the 3rd proviso to Sec.24(b) of the Act. On perusal of the provisions of section 24(b), it is clear that the deduction is allowed […]
Bombay Rayon Holdings Ltd. Vs ITO (ITAT Mumbai) Another issue in this regard for A.Y.2010-11 onwards is that the loan has been converted into share application money. In this regard, the ld. Counsel of the assessee has placed reliance upon several case laws that share application money is shareholder fund and no interest should be […]
DDIT Vs Mitsui & Co. Ltd. (ITAT Delhi) Learned DR contended that MIPL is economically dependent on assessee company as major revenue of MIPL is from assessee company. We are of the view that this per se cannot be ground to hold that MIPL is a Dependent Agent. For invoking this clause, first one of […]
Dart Infrabuild (P) Ltd. Vs ITO (ITAT Delhi) A conjointly reading of section 148 (1) of the Act with section 139 (4) of the Act and section 144 of the Act makes it abundantly clear that pursuant to the notice under section 148 of the Act, if an assessee files a belated return or letter […]
